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Anti-slavery and Human Trafficking Policy


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 for personal or commercial gain. Thrive is committed to acting ethically and with integrity in 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 chain.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain, consistent with the disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of 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. We ask our staff to be vigilant and look out for any signs of modern slavery when working or visiting our customers’ in their homes.


This policy applies to our employment arrangements, policies and procedures, the services delivered to our customers and the work/services procured through third parties.

Taking Responsibility

The Thrive Board 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 Leadership Management Team 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 slave.

Management 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 the supply chain

Spotting the signs

It’s everyone’s responsibility to look out for the signs of exploitation. Concerns can arise through our own observations or through our customers reporting concerns about others in the communities we operate. Thrive has a policy in place, Safeguarding and Vulnerable People Policy, within which we set out the process we will follow to alert the appropriate authority to potential criminal/exploitative behaviour.

Staff members should consider carefully for example when tender prices seem too low compared to other bidders. This could indicate staff working for the contractor are being underpaid. Other concerns might be when contractors seem to have a transient workforce which could imply poor employment terms or trafficking of some kind, or it could be the physical appearance of workers, looking scruffy, malnourished and/or showing signs of injuries or other forms of abuse. These examples won't always mean people are being exploited but unless we set out to assurance ourselves this isn’t the case we won’t know.

The HR Team will ensure as part of our onboarding process that anyone joining Thrive can provide the documentation necessary to prove they have the right to work in UK. In addition, the team will ensure our working arrangements are fully aligned to current UK legislation and best practice including The Working Time Regulations and Nation Living and Minimum Wage standards.

Act now – don’t wait

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of us all. Staff will be expected to avoid any activity that might lead to, or suggest, a breach of this policy.

Should you believe or suspect that a conflict with this policy has or will take place, you must act by contacting any member of the Thrive Governance Team or your line manager as soon as possible.

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

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 line manager or the Governance Team.

Thrive values being Open 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 chain.

The consequence of getting it wrong

We want to feel proud of everything we do ourselves and through our suppliers, therefore the consequence of breaching this policy has the potential to be severe.

Any member of staff 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.

Other Related Policies and Guidance

This policy links to other policies Thrive has in place, including but not limited to:

  • Whistleblowing
  • Code of Conduct
  • Equality and Diversity Policy
  • Disciplinary Policy
  • Recruitment Policy
  • Procurement Framework
  • Safeguarding and Vulnerable People Policy

As a business, we try hard to keep all these related policies aligned with each other. If you do spot any inconsistency, please do contact the Author at your earliest opportunity and make your concerns known. Your support to keep information clear and consistent will always be welcomed.

Policy Approval

As this policy is a core component of how Thrive manages its business the document will be evaluated by the Executive Management Team, the All Together@Thrive Working Group and Remuneration & Governance Committee as part of any review.

Support and Further Guidance

This policy has been drafted with input from staff across Thrive. If you have any concerns on how to interpret or follow its requirements, it’s your responsibility to make your concerns known to your manager or a member of the Governance Team.

Each Thrive team member has a responsibility to work in a way that’s consistent with the expectations set out in the documents and its implied intent. Should you witness or become aware of anyone consciously or unconsciously not following this policy you must alert your line manager or member of the leadership team as soon as is reasonably practical.