Modern slavery statement

Whether we are required to publish this

The duty to publish an annual modern slavery statement applies to a business with a total annual turnover of £36 million or more, counting the whole group wherever in the world it operates.

TBD — Bluebell’s group turnover. Until that is confirmed we cannot say whether the duty applies, so we publish this voluntarily and describe it as voluntary.

That distinction is not pedantry. A statement that says it is made “pursuant to section 54” when no duty exists misrepresents the law, and the Home Office’s own guidance warns against exactly that. If the threshold is crossed, this page needs the formal approval and signature the Act requires, a link from the homepage, and annual republication — and it will get all three.

The Immigration and Asylum Bill, introduced in June 2026 and still before Parliament, would make more of this mandatory: a prescribed list of topics every statement must cover, penalties for not publishing, and compulsory submission to the government registry. It has not become law, and we have not written this page as though it had.

Our business and where the risk actually sits

We support adults in supported living and in their own homes, we run children’s services, and we are developing residential care. Almost everything we buy is either labour or the ordinary supplies of running a home.

Being specific about where the risk is, rather than claiming there is none:

• International recruitment. Care workers recruited from overseas can arrive owing money to an agent, holding a visa tied to one employer, and afraid that raising a problem will cost them their right to remain. That combination is the single largest modern slavery risk in this sector and it sits inside the employment relationship, not out in a distant supply chain.
• Agency and bank staff. Where we do not recruit someone ourselves we are relying on another organisation’s checks.
• Subcontracted services. Cleaning, laundry, catering, maintenance and construction — sectors with known exploitation risks.
• The people we support. Adults at risk and children can be victims of trafficking or exploitation themselves. Modern slavery is one of the ten categories of abuse our safeguarding policy has to recognise, and our staff will be trained to spot it.

Recruitment

The checks a care provider must run anyway are also the ones that catch forced labour, which is why this section is the substantive one.

These are the checks we will run on every person before they start, and they are not aspirational: they are the recruitment file our regulator requires, and the same checks that catch forced labour.

• Right to work checked for everyone, before they start.
• An enhanced criminal record check, with the appropriate barred list, for every role that requires one.
• Identity, full employment history with gaps explained, references taken up directly, and qualifications verified — the recruitment file our regulator requires.
• Everyone paid at least the legal minimum, with hours inside working time limits, and paid directly into their own bank account. Never to a third party, never to an account shared with a recruiter, and never with a deduction we cannot explain.
• No worker charged a fee for finding them work, and no document — passport, permit, certificate — retained by us or by anyone acting for us.

Where an agency supplies staff, we require written confirmation that it has run the same checks.

How someone raises a concern

A statement is worth nothing if the person who sees something is afraid to say it. In law, a worker who reports something in the public interest is protected from being dismissed or treated badly for it, from their first day.

Internally: to a manager, or above them, or to the named person in our whistleblowing policy who sits outside the normal line of management.

Externally, and without telling us first: our regulator, or Protect, the independent whistleblowing charity, whose free confidential advice line is 020 3117 2520. Anyone who suspects someone is being held or exploited can also call the Modern Slavery Helpline, and in an emergency, 999.

TBD — the named internal contact, and the confirmed regulator route. We are not publishing a number we have not verified.

Suppliers

We choose established suppliers and expect them to hold their own suppliers to the same standard. Where a contract allows it we require confirmation that no forced or child labour is used, that workers are paid at least the legal minimum, and that working time rules are followed.

TBD — how far down our supply chain we have actually looked. “We assess the risk as low” is the standard sentence here and it is worth very little without saying what was examined to reach it. We would rather record the gap.

Training

Modern slavery is covered in safeguarding training, because for our staff it arrives as a safeguarding concern rather than as a procurement question — it is one of the ten recognised categories of abuse. Managers who recruit or who deal with agencies get more. TBD — the specific content and how often it is refreshed. No regulation sets a fixed interval, so this is a commitment Bluebell makes rather than one it inherits, and it should be stated as a real interval rather than as “regularly”.

Approval

Where the Act applies, a statement must be approved by the board and signed by a director, and that is a governance act rather than a form of words.

TBD — the approval date, the name and role of the person signing, and the financial year covered. Until those exist this page carries no approval formula, because writing one for a meeting that has not happened would be a false statement about the company’s own governance.