Slavery & Human Trafficking Statement.


Slavery & Human Trafficking Statement

This statement is made as part of Sanctuary Personnel's commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act), to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year to 31 October 2021.

Sanctuary Personnel recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.

1. Our business

Sanctuary Personnel Ltd is a limited company operating in the recruitment sector. Our business consists of recruitment across the health and social care sector. We supply temporary workers and act as a master vendor. Through the trading name of Innovate Services we deliver managed health and social work services. These services consist of statutory and non-statutory health and social work intervention.

Sanctuary Personnel is an independent business.

1.1. Who we work with

All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff. All of the temporary workers we supply are identified by our staff. Some of these work-seekers operate through their own limited companies. Some of our work-seekers are supplied via other businesses, who facilitate providing them to the eventual hiring company.

As a master vendor, we work with other businesses to supply workers to hiring companies. We hire some of the workers directly, who are directly recruited by our staff. Other workers are hired directly by other businesses. Some of these workers operate through their own limited companies. We facilitate supplying a mix of these workers to the hiring companies.

The hiring companies that we work with are located in various locations across the UK, Guernsey, Jersey, Isle of Man and the Falkland Islands. The workers we supply live in locations local to the clients we are working with.

1.2 Other relationships

As part of our business, we also work with the following organisations:

  • The Recruitment and Employment Confederation (

  • The British Association for Behavioural & Cognitive Psychotherapies (

  • The Online CBT Register (

  • The British Association of Counsellors & Psychotherapists (

  • The Health and Care Professions Council (

  • The Nursing and Midwifery Council (

  • The General Medical Council (

  • The Northern Ireland Social Care Council (

  • The Care Council for Wales (

  • The General Dental Council (

  • The Scottish Social Services Council (

  • The General Pharmaceutical Council (

  • Social Work England (

2. Our policies

In addition, to this Modern Slavery Policy Statement, Sanctuary Personnel has the following policies which incorporate ethical standards for our staff and our suppliers.

  • Whistleblowing policy. The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

  • Employee code of conduct. The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating nationally, internationally and managing its supply chain.

  • Supplier code of conduct. The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.

2.1 Policy development and review

Sanctuary Personnel’s policies are established by our directors and senior management team based on advice from HR professionals, industry best practice and legal advice. We review our policies annually or as needed to adapt to changes.

3. Our processes for managing risk

In order to assess the risk of modern slavery, we use the following processes with our suppliers:

When engaging with suppliers, where available, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing. When engaging with international suppliers we seek to do so firstly with those approved by the relevant registered body. If this is not possible any candidate needs to pass our own pre-employment checks with verified right to work documentation, identification and qualifications.

  • We conduct audits before entering into a commercial relationship with any business where there is the potential for risk. These audited businesses form the basis of our preferred supplier list.

  • We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.

After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.

Additionally, we have taken the following steps to minimise the possibility of any problems:

  • We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.

  • We require the businesses we work with to abide by our code of supplier conduct, address modern slavery concerns in their policies, publish a modern slavery statement.

  • We collaborate with our suppliers in order to improve standards and transparency across our supply chain.

  • Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.

  • We ensure that all of our suppliers are members of appropriate industry bodies and working groups.

  • Our staff are encouraged to bring any concerns they have to the attention of senior management.

4. Our performance

As part of monitoring the performance of Sanctuary Personnel we track the following general key performance indicators:

Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our senior management team:

  • The percentage of suppliers who provide their own modern slavery statements

  • The effectiveness of enforcement against suppliers who breach policies

  • The amount of time spent on audits, re-audits, spot checks, and related due diligence

  • The level of modern slavery training and awareness amongst our staff

We carefully consider our indicators in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.

5. Our training

All of our staff receive training and support that is appropriate to their role. In particular:

  • Our recruiters, HR professionals, senior management team and staff involved in our procurement and supply chains undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.

The organisations modern slavery training covers:

  • Our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;

  • How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;

  • How to identify the signs of slavery and human trafficking;

  • What initial steps should be taken if slavery or human trafficking is suspected;

  • How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;

  • What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;

  • What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and

  • What steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.

Training is refreshed annually.

As well as training staff, the organisation has raised awareness of modern slavery issues by circulating a series of emails to staff.

The emails explain to staff:

The basic principles of the Modern Slavery Act 2015;

  • How employers can identify and prevent slavery and human trafficking;

  • What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and

  • What external help is available, for example through the Modern Slavery Helpline.