Modern Slavery and Human Trafficking Statement
Introduction
Key supports adults and young people with disabilities and long-term conditions throughout Scotland. Good support is essential for a good life and we work alongside each person we support, and their family, to help them live life to the full.
This statement is published in accordance with the Modern Slavery Act 2015 and outlines the organisation’s commitment to ensuring that our activities and supply chain are free from modern slavery and human trafficking.
Modern Slavery
Modern slavery describes a range of exploitative practices including slavery, forced or compulsory labour, debt bondage and human trafficking. It refers to situations of exploitation that a person cannot refuse or leave often due to threats, violence, coercion, deception, or abuse of power and vulnerability.
Our Organisation and Supply Chain
Key is a charity and social care provider. We operate exclusively in Scotland, providing highly personalised support to people across 16 Local Authority areas. We are also a provider of good quality housing, offering a range of personalised housing solutions.
We act ethically and with integrity in all our business relationships and in our relationships with our employees.
We do not procure any goods and services directly from any countries which are at high risk of modern slavery or human trafficking, our suppliers being entirely UK-based.
Our supply chains considered most at risk of modern slavery are providers of agency staff and contractors in relation to our property maintenance activity.
Steps Taken
To reduce the risk of modern slavery in our organisation, we have a robust and transparent recruitment process which adheres to the Scottish Government’s Safer Recruitment guidance and the Scottish Social Services Council’s Code of Practice and which includes confirming candidates’ right to work in the UK, criminal records checks for the UK and, if appropriate, overseas, and obtaining employment references.
Our employees are employed on terms that are in accordance with applicable UK legislation. We aim to provide a secure and safe working environment, provide development and career opportunities, treat employees with respect, help employees achieve their maximum potential and compensate them fairly, with salaries paid directly into individual bank accounts.
We have systems in place to support staff to whistleblow any concerns and to deal with these promptly and effectively.
For our supply chain, we ensure that we engage only with reputable contractors and suppliers who adhere to the relevant regulations and legislation in the provision of their goods and services.
Providers of agency staff must adhere to the same high standard of recruitment practices, also abiding by the SSSC Code of Practice.
Our procurement strategy and processes are designed to ensure compliance with legal and regulatory requirements and adopt best procurement practice. Suppliers must comply with all relevant legislation and related regulations, industry codes of practice, be registered with the appropriate governing/regulatory body, and supply/employ only appropriately trained and qualified staff.
Suppliers are required specifically to comply with the provisions of the Modern Slavery Act and, in the event of their failure to do so, we are granted the right to terminate the contract.
Policies
We have a number of policies which through their implementation enable us to mitigate the potential risk of modern slavery within the course of our activities. These include our Recruitment policy, Dignity at Work policy, Equal Opportunities policy, Whistleblowing policy and Procurement policy.
Ongoing Commitment
We remain vigilant to the risk of modern slavery and human trafficking activities and are committed to continuous improvement of our processes. We shall continue to review our policies and procedures over the next financial year, seeking advice from appropriate sources such as the Equality and Human Rights Commission and the Trafficking Awareness Raising Alliance, and take such further appropriate steps to ensure slavery and trafficking are not present in our supply chain or in any part of our own activities.
Approval
This statement relates to the financial year ending on 31 March 2023. It was approved by Key’s Board on 23 August 2023 and is signed on their behalf.
Andrea Wood
Chief Executive
