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Modern Slavery Policy

Updated on 22nd December 2020


Anti-Slavery and Human Trafficking Policy  

Policy statement  

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such  as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in  common the deprivation of a person’s liberty by another in order to exploit them to personal or  commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to  acting ethically and with integrity to all our business dealings and relationships and to implementing  and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere  in our own business or in any of our supply chains.  

We are also committed to ensuring there is transparency in our own business and in our approach to  tackling modern slavery throughout our supply chains, consistent with our disclosure obligations  under the Modern Slavery Act 2015. We expect the same high standards from all our contractors,  suppliers and other business partners, and as part of our contracting processes, we include specific  prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or  servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers  to the same high standards.  

This policy applies to all persons working for us on our behalf in any capacity, including employees at  all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents,  contractors, external consultants, third-party representatives and business partners.  

This policy does not form any employee’s contract of employment and we amend it at any time.  Responsibility of the Policy  

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and  ethical obligations, and that all those under our control comply with it.  

The Procurement Manager has primary and day-to-day responsibility for implementing this policy,  monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control  systems and procedures to ensure they are effective in countering modern slavery.  

Line managers at all levels are responsible for ensuring those reporting to them understand and  comply with this policy and are given adequate and regular training on it and the issue of modern  slavery in supply chains.  

You are invited to comment on this policy and suggest ways in which it might be improved.  Comments, suggestions and queries are encouraged and should be addressed to the Procurement Manager. 

Compliance with the Policy  

You must ensure that you read, understand and comply with this policy.  

The prevention, detection and reporting of modern slavery in any part of our business or supply  chains is the responsibility of all those working for us or under our control. You are required to avoid  any activity that might lead to, or suggest, a breach of this policy.  

You must notify your Manager as soon as possible if you believe or suspect that a conflict with this  policy has occurred, or may occur in the future.  

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of  our business or supply chains of any supplier tier at the earliest possible stage.  

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify  your Manager or report it in accordance with our Whistleblowing Policy as soon as possible.  

If you are unsure about whether a particular act, the treatment of workers more generally, or their  working conditions within any tier of our supply chains constitutes any of the various forms of  modern slavery, raise it with your Manager or Procurement Manager.  

We aim to encourage openness and will support anyone who raises genuine concerns in good faith  under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers  any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery  of whatever form is or may be taking place in any part of our own business or in any of our supply  chains. Detriment treatment includes dismissal, disciplinary action, threats or other unfavourable  treatment connected with raising a concern. If you believe that you have suffered any such  treatment, you should inform the Procurement Manager immediately. If the matter is not remedied,  and you are an employee, you should raise it formally using our Grievance Procedure.  

Communication and Awareness of this Policy  

Training on this policy, and on the risk our business faces from modern slavery in its supply chains,  forms part of the induction process for all individuals who work for us, and regular training will be  provided as necessary.  

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors  and business partners at the outset of our business relationship with them and reinforced as  appropriate thereafter.  

Breaches of this Policy  

Any employee who breaches this policy will face disciplinary action, which could result in dismissal  for misconduct or gross misconduct. 

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy. 

Download this policy

Quality & Assurance

Assuring quality accommodation and care, the local senior management team at Kathryn Homes NI Limited works closely with associated external health and care agencies, regulators and authorities to ensure that all aspects of our care and nursing services meet the most up to date standards and guidelines.
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Kathryn Homes

Kathryn Homes Head Office
City View Court
2 Hopewell Avenue
BT13 1DR
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