Modern Slavery and Human Trafficking Statement
Financial year ending: July 2025

1) Our commitment

1st Enable has zero tolerance for all forms of modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing effective systems and controls to ensure slavery and human trafficking are not taking place in our own operations or in any of our supply chains.

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and sets out the steps we took during the financial year ending July 2025 to address the risk of modern slavery and human trafficking in our business and supply chains.

2) Who we are and what we do

Our services. 1st Enable provides supported living services to adults with learning disabilities. We work alongside each person to maximise independence, safety and quality of life.

Our footprint. We support around 200 individuals and employ approximately 450 colleagues across Cheshire, Merseyside, Greater Manchester, Yorkshire and Teesside.

Our supply chains. Our key supplier categories include:

• Health & social care staffing (UK recruitment, bank staff, occasional agency and international recruitment when required)
• Training and clinical supervision
• Medical consumables and equipment
• Property, maintenance and facilities management (including cleaning and waste)
• IT/telecoms and professional services

3) Governance and policies

• Accountability. Oversight of our approach rests with the Board. Day?to?day ownership sits with e.g. Assistant Director of Quality, with quarterly reporting to the Board.
• Policies. Our policy framework includes: Modern Slavery Policy, Safeguarding Adults and Children Policies, Safer Recruitment Policy, Whistleblowing (“Speak Up”) Policy, Anti?Bribery & Corruption Policy and a Supplier Code of Conduct. These collectively prohibit forced labour, recruitment fees, document retention, deception, intimidation and any form of coercion.
• Survivor?centred approach. Where harm is identified, we prioritise the immediate safety and wellbeing of affected workers and people we support, provide access to appropriate support, and pursue remediation with suppliers alongside regulatory and law?enforcement engagement.

4) Where our risks are

We recognise heightened risks in:

• Labour supply, particularly agency labour and any international recruitment (e.g., unlawful recruitment fees, debt bondage, coercive accommodation or transport, unfair deductions, passport retention).
• Outsourced services with complex, multi?tier supply chains.
• Safeguarding of people we support, who may themselves be targeted by traffickers or exploiters.

We assess risk using country/sector indicators, supplier self?assessments, contract reviews, grievance/channel insights, and (where appropriate) worker?voice checks (interviews/surveys).

5) Due diligence and controls

5.1 Suppliers and contractors

• All new suppliers must accept our Supplier Code of Conduct and warrant compliance with the Modern Slavery Act.
• Contracts include clauses requiring suppliers to prevent modern slavery, cascade equivalent obligations to sub?suppliers, and notify us of any incidents or investigations.
• We apply risk?based checks (enhanced questionnaires, audits/spot checks or third?party assurance where proportionate) to higher?risk categories: staffing/recruitment, PPE and catering.

5.2 Ethical recruitment

• We operate safer recruitment practices: verified right?to?work, DBS checks appropriate to role, transparent contracts, lawful pay, hours and deductions.
• We prohibit recruitment fees being charged to any worker we engage or that is supplied to us.
• Where international recruitment is used, we require ethical standards, including no fees to candidates, clear pre?employment information (role, pay, location, hours, deductions, accommodation options/costs) and post?arrival pastoral support. We expect any recruitment partners to meet recognised health and social care ethical recruitment standards.

5.3 Agency labour (if applicable)

• We will work only with reputable, regulated employment businesses that confirm compliance with UK employment and conduct regulations, including the prohibition on charging work?seekers fees.
• We require agency workers to receive clear assignment details, lawful pay (including holiday pay), and routes to raise concerns directly and confidentially.

6) Safeguarding, reporting and remediation

• Raising concerns. Colleagues, people we support, families, suppliers and the public can raise concerns via our Speak Up channel e.g. the local manager/safeguarding lead. We do not tolerate any detriment for speaking up in good faith.
• External reporting. Anyone can contact the UK Modern Slavery & Exploitation Helpline on 08000 121 700 or report concerns to the police (999 in an emergency, 101 otherwise).
• National Referral Mechanism (NRM). Where we suspect a person is a potential victim of modern slavery, we escalate promptly. Where we are not a designated First Responder, we work with the local authority/police so that an NRM referral can be made.
• Remediation. If an issue is identified in our operations or supply chains, we will: protect affected individuals; collaborate with authorities and specialist NGOs; require corrective actions (including fee reimbursement and ending retaliatory practices); and, where issues are not resolved, suspend or terminate the relationship.

7) Training and awareness

• All colleagues: modern slavery awareness is included in induction and periodic refresher training, covering warning signs, safe escalation and our reporting routes.
• Role?specific: managers, registered managers, HR/recruitment, procurement and contract managers receive targeted training on labour standards, ethical recruitment, supplier due diligence and responding to disclosures sensitively.
• Guidance & tools: we provide posters/job?aid checklists for services and a manager toolkit for handling suspected cases.

8) Measuring effectiveness (KPIs)

We track and report on:

• Percentage of new starters and managers completing modern slavery training within 60 days.
• Percentage of high?risk suppliers that have accepted our Code and completed due?diligence questionnaires.
• Percentage of agency partners annually attesting to compliance with conduct regulations (incl. no fees to work?seekers).
• Number of worker?voice engagements (interviews/surveys) undertaken with high?risk suppliers and follow?up actions closed.
• Number of concerns raised, time to resolution, and remediation outcomes (e.g., fees reimbursed, deductions corrected).
• Completion of post?arrival check?ins for any internationally recruited workers (target: 100%).

9) Actions taken during the year ending August 2025

• Develop and publish this statement
• Ready to issue Suppliers Code of Conduct; embedded strengthened modern slavery clauses in new/renewed contracts in high?risk categories.
• Conducted a risk?mapping exercise of our labour supply chain, requiring attestations and corrective actions where needed (non found).
• Delivering targeted training to management roles, and implemented a manager toolkit for suspected cases.
• Schedule to carry out unannounced worker?voice checks across our whole organisation.
• Established a cross?functional Modern Slavery Working Group reporting quarterly to the Board.

10) Priorities for the next 12 months

• Extend supplier screening and tier?2/3 mapping across PPE, laundry and catering.
• Pilot independent worker interviews with high?risk suppliers.
• Strengthen controls around accommodation and transport offered or arranged by suppliers.
• Enhance data and reporting for KPIs, including agency partner attestations and remediation tracking.
• Refresh colleague training materials and service posters; share learning from incidents and near?misses.

11) Approval and publication

This statement was approved by the Board of 1st Enable on 29^th July 2025 and is signed by:

Jeff Dawson
Chief Executive Officer
1st Enable
Date: 29^th July 2025