Modern Slavery and Human Trafficking Policy

1. Introduction

Sentra Care Staffing Limited is committed to acting ethically and with integrity in all of our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our business or the arrangements that support it.

Modern slavery is a criminal offence under the Modern Slavery Act 2015. It can take many forms, including servitude, forced or compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Our annual turnover falls below the threshold at which a slavery and human trafficking statement is required under section 54 of the Modern Slavery Act 2015. We have adopted this policy voluntarily because we believe the standard it sets is the right one for a business supplying workers into regulated care settings, and because our clients are entitled to see it.

This policy applies to all persons working for us or on our behalf in any capacity, including employees, directors, temporary workers, contractors, and any third party engaged in connection with the supply of our workers.

2. Our Business

Sentra Care Staffing Limited, company number 17220643, is an employment business based in England. We supply temporary workers to care providers and other health and social care organisations across the United Kingdom. Our workers are engaged in complex care, domiciliary care, supported living, and other regulated care settings.

As an employment business we are the employer of the temporary workers we supply. We are responsible for their engagement, their pay, and their welfare while they are on assignment. That places obligations on us that go beyond those of a business that simply makes introductions, and this policy reflects that.

We operate in a sector where workers can be vulnerable to exploitation, particularly those who are new to the United Kingdom, those whose immigration permission is tied to a sponsor, and those who are unfamiliar with their rights under UK employment law. We take that risk seriously and take active steps to identify, prevent and address it.

3. Our Commitment

Sentra Care Staffing Limited operates a zero tolerance approach to modern slavery and human trafficking. We are committed to the following.

Acting ethically and with integrity in all of our business dealings and relationships.

Implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our business or in the arrangements that support it.

Charging no recruitment fee, placement fee, registration fee, or associated cost to any worker at any point, in accordance with the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

Ensuring that all workers are engaged freely and of their own choosing, and are able to end their engagement with us without penalty, threat, or the withholding of pay or documents.

Never retaining a worker’s passport, identity documents, or other personal property.

Paying every worker at least the applicable National Minimum Wage or National Living Wage, and making no deduction from pay that is not lawful and clearly agreed in writing in advance.

Verifying the right to work of every worker in accordance with UK immigration legislation before any assignment begins.

Carrying out enhanced Disclosure and Barring Service checks on all workers engaged in regulated care activities.

Respecting the limits set by the Working Time Regulations 1998 and monitoring the hours our workers actually work.

Reporting any actual or suspected incident of modern slavery to the relevant authorities promptly.

4. Risk Assessment

We take a risk based approach to identifying modern slavery risk in our business. The key areas we have identified are set out below.

4.1 Recruitment and Onboarding of Workers

The recruitment of workers, particularly those who have recently arrived in the United Kingdom or who are introduced to us by a third party, carries an inherent risk of exploitation. We mitigate this risk by carrying out our own right to work and identity verification on every worker rather than relying on assurances from anyone else, by meeting or speaking directly with every worker before engagement, and by confirming that no fee has been charged to the worker by anyone in connection with their placement.

Where a worker has been referred to us by another party, we ask the worker directly whether they have been asked to pay anything, whether they hold their own identity documents, and whether they are free to leave their current living or working arrangements. Any answer that gives us cause for concern is escalated to the Director before the worker is engaged.

4.2 Engagement and Payment of Workers

All workers supplied by Sentra Care Staffing Limited are currently engaged and paid on a PAYE basis. We do not at present engage workers through umbrella companies, personal service companies, or any other intermediary. This is a deliberate choice, because paying workers directly gives us complete visibility of what each worker actually receives.

Should our engagement model change in future and we decide to work with an umbrella company, we will only do so where that provider is accredited by a recognised industry body such as the Recruitment and Employment Confederation or the Freelancer and Contractor Services Association. Before any such provider is engaged we will carry out documented due diligence covering its ownership, its compliance record, its pay and deduction practices, and its own modern slavery controls. We will require written confirmation of compliance with the Modern Slavery Act 2015 and with this policy, we will require transparency of every deduction made from worker pay, and we will keep the arrangement under active review. No intermediary will be introduced into our arrangements without the express approval of the Director.

The same standard applies to any sub-contractor or other third party we might engage in connection with the supply of workers.

4.3 Workers Holding Sponsored or Time Limited Immigration Permission

Workers whose permission to be in the United Kingdom is tied to a sponsor or is otherwise time limited are more vulnerable to exploitation, because the consequences of losing work can extend to losing the right to remain. The health and social care sector has seen well documented abuse of sponsorship arrangements, and we treat this as a live risk rather than a theoretical one.

Where we engage a worker in this position we take particular care to confirm that the worker holds their own documents, that they have not paid any fee in connection with their sponsorship or their work, that they are not carrying a debt to any party connected with their arrival in the United Kingdom, that they are not working in excess of the hours their permission allows, and that they understand they can raise a concern with us confidentially and without any effect on their engagement.

4.4 The Assignment Environment

Our workers carry out their duties in the homes of the people they support and on client premises, often working alone and away from direct supervision by us. We maintain regular contact with workers on assignment, we check in independently of the client, and we make it straightforward for a worker to speak to us about anything that concerns them, including anything they observe about the treatment of other workers on site.

5. Due Diligence and Controls

In support of the commitments set out above, Sentra Care Staffing Limited applies the following controls as a matter of routine.

Right to work verification for every worker before engagement, carried out by us and recorded.

Enhanced Disclosure and Barring Service checks for every worker placed in a regulated care setting.

Full employment history and reference checks in line with safe recruitment practice for health and social care.

Written terms of engagement issued to every worker before they start, setting out pay, hours, and rights in plain English.

Payment made directly to a bank account held in the worker’s own name, with any request to pay a third party or a shared account escalated to the Director and investigated before payment.

Ongoing monitoring of hours worked, pay received, and deductions applied.

Regular welfare contact with workers on assignment, independent of the client.

A confidential route through which any worker can raise a concern without fear of reprisal.

Documented due diligence on any third party engaged in connection with the supply of workers, and written confirmation of their compliance with this policy and the Modern Slavery Act 2015.

Full co-operation with any compliance audit or investigation carried out by a client or a client’s appointed auditor.

6. Training and Awareness

Sentra Care Staffing Limited ensures that all staff understand the risks of modern slavery and human trafficking, know what the warning signs look like in a staffing context, and understand their responsibility to report any concern. Training is provided at induction and refreshed annually.

Any member of staff who suspects that modern slavery or human trafficking is taking place, whether in our own business or in any arrangement connected to it, must report this to the Director immediately. Reports may also be made anonymously through our grievance procedure. We will not tolerate retaliation of any kind against anyone who raises a genuine concern in good faith.

7. Reporting and Whistleblowing

Any person who believes that modern slavery or human trafficking is occurring within Sentra Care Staffing Limited, or in connection with our business, should report it immediately to:

Danny Blake, Founder & Director

Email: danny@sentra-care.com

Telephone: 07943 834255

Where there are reasonable grounds to suspect that a criminal offence has been committed, we will report the matter to the relevant authorities. Concerns may also be raised independently of us with the Modern Slavery and Exploitation Helpline on 08000 121 700, which operates at all hours, or with the police.

8. Compliance and Monitoring

This policy will be reviewed annually by the Director of Sentra Care Staffing Limited, or sooner if there is a change in legislation, regulatory guidance, or the nature of our operations. A change to our worker engagement model, including any decision to work with an umbrella company, will trigger an immediate review.

Sentra Care Staffing Limited will co-operate fully with any audit, assessment, or investigation carried out by our clients or their appointed auditors for the purpose of verifying compliance with this policy and with the Modern Slavery Act 2015.

Breach of this policy by any employee, worker, contractor, or third party will be treated as a serious matter and may result in disciplinary action, termination of contract, or referral to the relevant authorities.

9. Statement of Commitment

This policy has been approved by the Director of Sentra Care Staffing Limited and represents our commitment to preventing modern slavery and human trafficking in all its forms within our business and in every arrangement connected to it.

Signed,

Danny Blake

Founder & Director, Sentra Care Staffing Limited

Date: August 2026