1. Introduction

Migrant Help exists to protect people affected by displacement and exploitation and is thus well positioned to take a holistic approach to address the issue of modern slavery. We work with survivors; we are first responders in identifying potential victims among our service users and we have a renewed commitment to understanding the risks within our own operations and supply chains.

This statement sets out Migrant Help’s approach to combating modern slavery, human trafficking and forced labour for the financial year ended 31 March 2022. It sets out the steps that Migrant Help and its subsidiary Clear Voice Interpreting Services have taken and are continuing to take to ensure that modern slavery does not occur within our operations or supply chain.

2. Organisation’s Structure & Supply Chains

Migrant Help is a UK wide charity delivering a range of support and advice services to vulnerable migrants. We operate from 10 offices across the UK, providing advice, guidance and support to asylum seekers, refugees, EU migrants and victims of modern slavery and human trafficking. We also operate a small number of accommodation units to support survivors of trafficking as part of our work for the National Referral Mechanism under the Modern Slavery Victim Care Contract.

Migrant Help is governed by a Board of Trustees who volunteer their time to help direct our work. They oversee our Directors who manage our 300+ staff across the charity. We have one wholly owned trading subsidiary, Clear Voice Interpreting Services, that operates a pool of over 500 self- employed interpreters.

We purchase IT services, stationery, small quantities of branded merchandise, furniture for accommodation and other office equipment, together with cleaning, maintenance, and professional services. We also subcontract some work to other organisations and charities, such as some call centre services and projects to support our service users.

3. Governance & Policies

Migrant Help plays a vital role in supporting survivors of modern slavery through our core activities. We also promote ethical practices, due diligence, and engagement within our supply chain.

We expect our suppliers to share our high standards towards ethical behaviour which includes, but is not limited to, adhering to Modern Slavery laws, and creating an environment that does not punish whistle-blowers.

Our approach is supported by the following policies, which set out the standards of behaviour expected of all Migrant Help staff, establish requirements of our suppliers and provide guidance for staff to report any concerns or suspicions of modern slavery.

  • Our Modern Day Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships. The Chief Executive and the Senior Management Team are responsible for ensuring that the policy is implemented throughout Migrant Help and reviewed annually.
  • Our Procurement Policy sets out Migrant Help’s requirements for buying goods and services, including the need to consider ethical considerations and to factor in Migrant Help’s commitment to the Living Wage.
  • Our Supplier Code of Conduct establishes the standards we expect of our suppliers, including those who may come into contact with our vulnerable service users. It also sets out our commitment to support suppliers in developing their approach to compliance with the Modern Slavery Act 2015, to promote Human Rights in accordance with the Human Rights Act (1998). and to reduce the risk of child labour and other labour exploitation.
  • Our Whistleblowing Policy encourages staff to report any concerns confidentially and without any fear of victimisation or retaliation.
  • Our Safeguarding Policy ensures that the safeguarding of adults and children, including victims of modern slavery, is well understood by all staff and, importantly, is acted on in an appropriate and timely manner to ensure the protection of our clients and our staff.
  • Our Anti- Corruption and Bribery Policy aims to protect individuals, including our clients, from being exploited in return for favours from our organisation.

4. Identification & mitigation of risks

Migrant Help regularly reviews risks and has recently begun a more in-depth process of mapping and assessing our supply chain for modern slavery risk.

Occasionally we use agency staff and, when we do, we use pre-vetted agencies. In addition, all staff are required to complete Disclosure and Barring Service (DBS) checks as a condition of employment.

Due to the nature of our work some of our clients are at high risk and some are identified as potential or actual victims of modern slavery. In these cases, we ensure that there are robust risk management and safeguarding procedures in place for the protection of clients and staff.

We remain vigilant for ways to improve our processes to mitigate risks and, to build our understanding of potential risks in our supply chain, we are taking the following steps:

  • Conducting a risk assessment on all suppliers beginning with those in higher risk categories and developing metrics to ensure they are committed to mitigating risks of modern slavery within their organisations and supply chains
  • Developing a system of annual supply chain assessment
  • Establishing consistent procedures to mitigate potential risks of modern slavery and embedding in our existing business procedures
  • Training 100% of staff on modern slavery in 2021

5. Due diligence processes

Due diligence checks are undertaken on prospective and current suppliers and subcontractors to Migrant Help. Our approach is to promote continuous improvement, acknowledging that new risks may arise as we continue operations and committing to act swiftly to mitigate those risks. The requirements in our Supplier Code of Conduct form part of the contractual terms signed by all subcontractors and suppliers.

For example, under our main contract with the Home Office to support asylum seekers, AIRE(1), all subcontractors are required to complete a questionnaire to demonstrate their track record and adherence to ISO standards during the tender process. We review their safeguarding policies, accounts and insurance documentation and they are then audited to ISO standards and other ethical requirements every year by Migrant Help’s Quality Team.

We respond swiftly and professionally to any concerns raised by clients, staff or suppliers, which would include any concerns about the potential for modern slavery within our supply chains and service areas. We also hold regular review meetings and willingly provide our expertise on modern slavery matters as needed to our suppliers.

In 2021, we are working to expand our vetting process for suppliers of services. This includes initial and annual risk assessments, a checklist of ISO compliance prior to contract agreement, and an audit schedule.

6. Measuring effectiveness

Our Senior Management Team annually reviews the effectiveness of our measures for ensuring that risks of slavery and human trafficking within our operations and supply chains are addressed and reports to the Board of Trustees accordingly.

In 2020, Migrant Help commissioned an independent review of safeguarding to ensure that the policy and procedures were well understood and correctly implemented. The review praised Migrant Help’s approach and identified a few minor areas for improvement, which we have now acted upon.

The effectiveness of Migrant Help’s performance under the Modern Slavery Victim Care Contract is measured through a set of KPIs that seek to ensure the needs of clients are prioritised. These are built into Migrant Help’s contract with The Salvation Army and are monitored monthly. This is supplemented by regular audits from the Care Quality Commission (CQC).

7. Communication and Training

All employees and new joiners receive training on all modern slavery related policies and copies of the employee handbook providing information about our policies.

We provide annual eLearning on modern slavery and human trafficking for all staff at Migrant Help and a quiz to assess their understanding. Our training includes knowing what modern slavery is, how to identify potential cases and how to report issues. In 2020, 84% of our staff received training on modern slavery.

Our staff responsible for delivering services directly to survivors receive additional specialised training, including Modern Slavery Guidance to aid in recognising potential cases.

Our regional staff offices each have a member of staff who is the lead on matters regarding modern slavery and who can provide guidance and information on issues and referrals within their team.

Migrant Help also provides specific advice and guidance to Migrant Help staff who have procurement responsibilities.

Our training programme is supplemented by ongoing internal communications through blogs, videos, and face-to-face engagement, that brings the topic of modern slavery to life and reinforces staff responsibilities in relation to addressing it.

8. Relevant Policies

  • Anti-Corruption and Bribery Policy
  • Modern Day Slavery Policy
  • Procurement Policy
  • Safeguarding Policy
  • Supplier Code of Conduct
  • Whistleblowing Policy

This Modern Slavery Statement has been approved by the Board of Trustees and is signed by Caroline

O’Connor, the charity’s Chief Executive.

1 Advice, Issue Reporting and Eligibility Assistance