Modern Slavery and Human Trafficking Policy

At Serenity Alley Healthcare, we are unwavering in our commitment to upholding the highest standards of ethical conduct, integrity, and respect for human rights. We recognize that modern slavery and human trafficking are among the most egregious violations of fundamental human rights, involving practices such as forced labor, debt bondage, servitude, and exploitation through trafficking. These abuses deny individuals their dignity and freedom, which are rights inherent to all people.

We acknowledge the critical role businesses play in identifying, addressing, and mitigating the risks of modern slavery within their operations and supply chains. As such, we are dedicated to fostering a culture of accountability, transparency, and respect for ethical practices at every level of our organization. This commitment extends beyond compliance with legal requirements and reflects our broader responsibility to positively contribute to the fight against modern slavery on a global scale.

In alignment with the Modern Slavery Act 2015, this policy serves as a declaration of our ongoing efforts to prevent and combat modern slavery across all aspects of our operations. It highlights the proactive measures we take to identify potential risks, ensure due diligence within our supply chains, and hold ourselves and our business partners to the highest standards.

Furthermore, we recognize the importance of collaboration and engagement with employees, suppliers, stakeholders, and the wider community to effectively address this pressing issue.

Through this policy, Serenity Alley Healthcare reaffirms its commitment to operating responsibly, ensuring that our practices do not contribute to exploitation, and advocating for ethical and sustainable practices both internally and externally. We believe that by setting a strong example and taking decisive action, we can play a meaningful role in eliminating modern slavery and promoting human dignity and equality in every aspect of our business operations.

Our Commitment

At Serenity Alley Healthcare, we are steadfast in our mission to combat modern slavery and human trafficking by embedding ethical practices into every facet of our operations. We pledge to uphold the following commitments:

1. Compliance with Legal Standards

We ensure that all aspects of our operations and supply chains comply with relevant laws and regulations, including the Modern Slavery Act 2015. This includes adhering to national and international standards that safeguard human rights and promote fair labor practices.

• Raising Awareness

We actively promote awareness of the risks and realities of modern slavery among our employees, stakeholders, and partners. Through training, clear communication, and educational initiatives, we aim to empower individuals within our organization to identify and address potential instances of exploitation.

• Ethical Partnerships

We are committed to working with suppliers and business partners who share our dedication to ethical and responsible practices. By conducting thorough due diligence and maintaining open communication, we strive to ensure our partners meet high standards of integrity and accountability in their operations.

• Continuous Improvement

We continually evaluate and enhance our policies, processes, and procedures to prevent any form of exploitation within our operations and supply chains. Through regular assessments, stakeholder feedback, and the adoption of best practices, we aim to strengthen our efforts to combat modern slavery effectively.

By upholding these commitments, Serenity Alley Healthcare demonstrates its dedication to creating a safe, fair, and transparent environment for all those impacted by our business activities. We believe that a proactive and collaborative approach is essential to driving meaningful progress in eradicating modern slavery and fostering a culture of respect, dignity, and responsibility.

Scope of the Policy

This policy defines the responsibilities and expectations of all individuals and entities associated with Serenity Alley Healthcare in our collective effort to combat modern slavery and human trafficking. It applies to the following groups:

• Employees

This includes all individuals working directly for Serenity Alley Healthcare, such as full-time and part-time employees, temporary staff, contractors, volunteers, and agency workers. All employees are required to understand and uphold the principles outlined in this policy, ensuring their actions and conduct align with our zero-tolerance approach to modern slavery.

• Suppliers and Partners

This encompasses all third-party suppliers, subcontractors, and business partners involved in providing goods or services to Serenity Alley Healthcare. These entities must adhere to the ethical standards set forth in this policy and demonstrate a commitment to eradicating exploitative practices from their own operations and supply chains.

Compliance with this policy is mandatory for everyone associated with Serenity Alley Healthcare. We expect all individuals and entities within our business ecosystem to actively

uphold the principles of transparency, accountability, and respect for human rights. Any failure to comply with this policy or tolerate modern slavery in any form will not be accepted and may result in the termination of business relationships or employment.

By setting clear expectations and fostering a culture of zero tolerance, Serenity Alley Healthcare reinforces its dedication to ethical practices and the elimination of modern slavery at every level of its operations and partnerships.

Our Approach

To prevent modern slavery and human trafficking, Serenity Alley Healthcare has adopted a comprehensive and proactive approach, which includes the following measures:

1. Risk Assessment and Due Diligence

• Regular Assessments: We conduct ongoing evaluations of our supply chains and business operations to identify areas where the risk of modern slavery may be higher. These assessments allow us to pinpoint potential vulnerabilities and take timely action.
  • Due Diligence Processes: Serenity Alley Healthcare has established robust due diligence processes to thoroughly evaluate suppliers’ compliance with ethical and legal standards. This involves reviewing their policies, labor practices, and certifications to ensure alignment with our values.
  • High-Risk Supplier Monitoring: We prioritize enhanced scrutiny for suppliers operating in high-risk regions or industries known to be more vulnerable to exploitation. Additional checks and monitoring are implemented to ensure these suppliers meet our ethical and operational requirements.

By implementing these measures, Serenity Alley Healthcare aims to address risks effectively, foster accountability, and uphold our commitment to ethical practices across all operations and partnerships.

2.   Policies and Procedures

To further strengthen our commitment to preventing modern slavery and human trafficking, Serenity Alley Healthcare has implemented the following policies and procedures:

• Integration of Anti-Slavery Provisions: We have incorporated anti-slavery clauses and provisions into our procurement processes, employee handbooks, and operational guidelines. These provisions ensure that all staff, suppliers, and business partners are fully aware of our zero-tolerance stance on modern slavery and are held accountable for maintaining ethical practices in all areas of their work.

• Clear Reporting Procedures: Serenity Alley Healthcare has established clear and accessible reporting procedures for employees, suppliers, and stakeholders to report suspected cases of modern slavery. These procedures are designed to facilitate prompt and effective action, ensuring that any concerns are addressed quickly and appropriately, while safeguarding the rights of those reporting.
  • Whistleblowing Policy: We maintain a secure and confidential whistleblowing policy that encourages the safe and anonymous reporting of any concerns related to modern slavery or unethical practices within the organization. This policy ensures that individuals can report any issues without fear of retaliation or adverse consequences, fostering a transparent and responsible working environment.

By integrating these policies and procedures into our daily operations, Serenity Alley Healthcare ensures that all potential risks related to modern slavery are identified and addressed promptly, and that our staff and partners have the necessary tools and protections to act against exploitation in any form.

3.   Training and Awareness

Serenity Alley Healthcare is committed to fostering a well-informed and vigilant workforce and supply chain. To achieve this, we have implemented a comprehensive approach to training and awareness that includes the following measures:

• Regular Employee Training: We provide ongoing training to all employees to ensure they understand how to identify and report potential modern slavery risks. This training covers a range of topics, including recognizing signs of exploitation, understanding relevant laws and regulations, and knowing the appropriate steps to take if they suspect any form of modern slavery in the workplace or supply chain.
  • Supplier and Partner Education: We work closely with our suppliers and business partners to ensure they understand their responsibilities in preventing exploitation and modern slavery within their operations. This includes offering educational resources and conducting training sessions to help them align their practices with our ethical standards and legal requirements.
  • Awareness Campaigns: To reinforce our anti-slavery message across the organization, we utilize various tools such as posters, workshops, and informational resources. These materials are designed to continually raise awareness about the dangers of modern slavery, encourage vigilance, and remind everyone within our organization and supply chain of the importance of ethical conduct and reporting mechanisms.

Through these initiatives, Serenity Alley Healthcare ensures that all employees, suppliers, and stakeholders are equipped with the knowledge and tools necessary to prevent, identify, and respond to modern slavery, thereby creating a culture of awareness, accountability, and action.

4.   Supplier Standards

Serenity Alley Healthcare is committed to ensuring that our suppliers uphold the highest ethical standards in their operations, particularly in relation to preventing modern slavery and human trafficking. To achieve this, we have established the following supplier standards:

• Supplier Commitment Agreements: We require all suppliers to sign formal agreements that commit to complying with the Modern Slavery Act 2015 and adhering to Serenity Alley Healthcare’s ethical standards. These agreements clearly outline our expectations regarding labor practices, human rights, and the prohibition of modern slavery within their operations.
  • Collaborative Improvement: We actively work with our suppliers to help them improve their labor practices and address any potential compliance gaps. Through regular communication and support, we provide guidance on how suppliers can meet our standards, while also offering assistance in developing strategies to eliminate any exploitation or unethical practices within their supply chains.
  • Termination of Non-Compliant Relationships: In instances where suppliers fail to meet our ethical standards or refuse to comply with our requirements, Serenity Alley Healthcare reserves the right to terminate the business relationship. We maintain a zero-tolerance policy towards modern slavery, and we are committed to working exclusively with suppliers who demonstrate a genuine commitment to ethical practices and the prevention of exploitation.

Through these supplier standards, Serenity Alley Healthcare ensures that every entity within our supply chain is held accountable for maintaining ethical and responsible labor practices, reinforcing our commitment to eradicating modern slavery and promoting human dignity and fairness in all aspects of our business.

5.   Monitoring and Reporting

To ensure that Serenity Alley Healthcare’s commitment to combating modern slavery is consistently upheld throughout our operations and supply chains, we have implemented a robust monitoring and reporting framework. This framework includes the following key actions:

• Regular Audits: We conduct periodic audits of our suppliers and contractors to assess their compliance with our ethical standards and identify any potential risks related to modern slavery. These audits are designed to verify that suppliers are following responsible labor practices, and to ensure that any violations are detected and addressed promptly.
  • Tracking Key Performance Indicators (KPIs): We monitor key performance indicators (KPIs) such as audit completion rates, the number of identified risks, and the status of risk resolution. These metrics help us track the effectiveness of our anti-slavery initiatives and provide insight into the areas that require improvement. By regularly reviewing these KPIs, we can take targeted action to strengthen our efforts and ensure that risks are mitigated effectively.

• Multiple Reporting Channels: Serenity Alley Healthcare provides various confidential and accessible reporting channels for employees, suppliers, and other stakeholders to report concerns or suspected breaches related to modern slavery. These channels are designed to ensure that individuals can raise issues in a safe and secure manner, without fear of retaliation. We are committed to investigating all reports thoroughly and taking appropriate actions when necessary.

By implementing these monitoring and reporting measures, Serenity Alley Healthcare ensures a high level of transparency, accountability, and continuous improvement in our efforts to combat modern slavery and human trafficking, both within our organization and across our supply chains.

Reporting and Response Mechanisms

Serenity Alley Healthcare takes any suspicion of modern slavery or human trafficking within our operations or supply chains very seriously. We are committed to responding swiftly and effectively to such concerns. To ensure that individuals can report any issues confidentially and without fear of retaliation, we have established several clear reporting channels:

• Whistleblowing Hotline: Reports can be made anonymously via our dedicated whistleblowing hotline at 0800 002 9721. This service is available 24/7 and ensures that individuals can report concerns in complete confidence.
  • Email: Individuals can also send confidential reports to modernslavery@serenityalley.co.uk. This email account is monitored regularly, and all correspondence will be handled with the utmost discretion.
  • Online: For added convenience, reports can be submitted via our secure online platform at www.serenityalley.co.uk. This platform allows individuals to submit their concerns easily and securely, ensuring that all reports are documented and addressed in a timely manner.

All reports of modern slavery or human trafficking will be taken seriously. Each report will be thoroughly investigated, and appropriate actions will be taken to address any issues raised. In cases where necessary, we will cooperate with authorities and law enforcement agencies to ensure that any illegal activities are dealt with according to the law.

By providing these multiple channels for reporting, Serenity Alley Healthcare ensures that individuals can feel confident in raising concerns, knowing that their reports will be handled with the utmost seriousness, confidentiality, and prompt action.

Governance and Accountability

At Serenity Alley Healthcare, the senior leadership team holds ultimate responsibility for ensuring that this policy is fully implemented and adhered to across the organization. Their role in promoting compliance with the policy includes the following key responsibilities:

• Overseeing Risk Assessments, Audits, and Training Programs: The senior leadership team ensures that regular risk assessments are conducted, audits of suppliers and contractors are completed, and training programs are delivered to employees, suppliers, and partners. They are accountable for ensuring that these processes are thorough and effective in identifying and mitigating risks related to modern slavery and human trafficking.
  • Reviewing Policy Effectiveness and Recommending Improvements: The senior leadership team is tasked with regularly reviewing the effectiveness of this policy and the steps taken to prevent modern slavery. This includes evaluating the outcomes of risk assessments, audits, and training programs, as well as identifying areas for improvement. They will recommend any necessary changes to enhance the policy and adapt it to evolving challenges or emerging risks.

To ensure ongoing relevance and compliance, the policy will be reviewed annually or updated as needed to reflect any changes in legislation, organizational structure, or operational requirements. This review process ensures that Serenity Alley Healthcare remains proactive in the fight against modern slavery and human trafficking, maintaining the highest standards of ethical conduct and accountability.

Steps to Prevent Modern Slavery

Serenity Alley Healthcare is committed to taking proactive steps to prevent modern slavery and human trafficking within our organization and supply chain. We have implemented the following key measures to safeguard against exploitation:

1. Employee Screening

We conduct rigorous pre-employment checks for all potential employees to ensure that they are working voluntarily, are not being coerced, and have the legal right to work. These checks include verifying identity, right-to-work status, and references, as well as ensuring that no individuals are being exploited or subjected to forced labor at any stage of the recruitment process.

2. Ethical Recruitment

Serenity Alley Healthcare partners exclusively with reputable and ethically responsible recruitment agencies that adhere to strict anti-slavery policies. We ensure that these agencies share our commitment to ethical recruitment practices, including the prohibition of fees charged to workers and the assurance that all candidates are treated fairly, with dignity and respect.

3. Supply Chain Verification

Before entering into any business agreements with suppliers, we require that they demonstrate clear compliance with our ethical standards, including policies that prevent modern slavery. We assess suppliers’ labor practices, conduct audits, and verify their commitment to upholding human rights within their operations. We prioritize working with suppliers who are transparent

about their practices and who take proactive steps to eliminate any form of exploitation in their supply chains.

These steps are integral to our broader efforts to maintain a zero-tolerance policy towards modern slavery, ensuring that all aspects of our business operations and partnerships are aligned with ethical standards and legal requirements. By taking these preventive measures, Serenity Alley Healthcare strives to create a safe and fair environment for all individuals involved in our workforce and supply chains.

Raising Awareness

At Serenity Alley Healthcare, we recognize the importance of raising awareness about modern slavery and its detrimental effects on individuals and communities. We are committed to ensuring that all employees, suppliers, and stakeholders are well-informed and equipped to identify and address any risks related to exploitation. Our approach to raising awareness includes the following key initiatives:

•  Distributing Educational Materials

We provide employees and suppliers with comprehensive educational materials on modern slavery, human trafficking, and ethical labor practices. These resources are designed to inform and educate all parties about the signs of exploitation, the legal frameworks in place to prevent it, and the actions they can take to help combat modern slavery. Regular updates and training ensure that the information remains relevant and impactful.

•  Participating in Industry-Wide Initiatives

Serenity Alley Healthcare actively engages in industry-wide initiatives, forums, and collaborative efforts to address the risks of exploitation. By working together with other organizations, governmental bodies, and advocacy groups, we contribute to a collective effort to raise awareness and promote best practices across our industry. Participation in these initiatives allows us to stay informed about emerging threats and share insights with others in the sector.

•  Fostering Open Dialogue and Encouraging Reporting

We create a supportive environment where employees are encouraged to speak openly about modern slavery and its risks. We foster a culture of transparency by ensuring that all concerns are treated seriously, and we actively encourage employees to report any suspected incidents of exploitation without fear of retaliation. This open dialogue helps to strengthen our collective efforts to detect and eliminate modern slavery within our operations and supply chains.

By implementing these awareness-raising strategies, Serenity Alley Healthcare ensures that modern slavery is not tolerated within our organization or supply chains. We strive to empower our workforce and partners to take informed, decisive action in the fight against exploitation.

Penalties for Non-Compliance

Serenity Alley Healthcare maintains a zero-tolerance policy towards modern slavery and human trafficking. Any violation of this policy by employees, suppliers, or business partners will not be tolerated and will result in serious consequences. The following penalties will be enforced for non-compliance:

• Termination of Contracts

Any employee, supplier, or business partner found to be in breach of this policy may have their contract terminated immediately. For employees, this may result in dismissal, while suppliers or business partners may have their agreements or business relationships with Serenity Alley Healthcare severed. We will not engage with any parties that do not share our commitment to ethical practices and the eradication of modern slavery.

• Reporting to Relevant Authorities

In cases where there is evidence of illegal activity or exploitation, Serenity Alley Healthcare will report the matter to the appropriate authorities, including law enforcement agencies and regulatory bodies. This ensures that the issue is handled according to the law and that necessary legal actions are taken to protect victims of modern slavery and trafficking.

• Legal Action

In addition to terminating contracts and reporting to authorities, Serenity Alley Healthcare may pursue legal action where applicable. If any individual or entity is found to be engaged in modern slavery or trafficking, we will take all necessary legal steps to hold them accountable, including pursuing civil or criminal litigation, as permitted by law.

These penalties ensure that Serenity Alley Healthcare remains a responsible, ethical organization and reinforces our commitment to preventing modern slavery. Through these actions, we aim to maintain a safe, fair, and transparent environment for all those involved in our business.

Policy Review and Approval

This policy has been formally approved by the senior leadership team at Serenity Alley Healthcare and is integral to our ongoing efforts to prevent modern slavery and human trafficking. We are dedicated to ensuring that this policy remains relevant, effective, and aligned with current legal and ethical standards. As such, it is subject to annual review and updates to reflect changes in legislation, organizational practices, or any identified risks related to modern slavery.

• Policy Effective Date: 8 October 2024

• Last Reviewed: 14 December 2024

• Approved By: Clara Vale, Head of HR

• Contact: HR@serenityalley.co.uk

At Serenity Alley Healthcare, we remain firmly committed to our zero-tolerance approach to modern slavery and human trafficking. Our primary objective is to promote ethical business practices and to protect the dignity, rights, and well-being of every individual involved in our operations, supply chains, and partnerships. We understand that the fight against modern slavery requires continuous vigilance and cooperation, and we are dedicated to leading by example in upholding the highest standards of human rights across all areas of our business.