GCCGL Modern Slavery and Human Trafficking Statement
Our Commitment
Modern slavery includes slavery, servitude, human trafficking, and forced labour. Gilead Complete Care
Group Limited has a zero-tolerance approach to any form of modern slavery or human trafficking. We are
committed to acting ethically, with integrity and transparency, and to putting in place effective systems
and controls to prevent slavery and human trafficking from occurring anywhere in our organisation or our
supply chains.
Our Organisation
Gilead Complete Care Group Limited is a CQC-registered health and social care provider, delivering care
services across various locations in the United Kingdom. We are committed to providing high-quality,
person-centred care that upholds the dignity, rights, and wellbeing of every individual. We recognise our
responsibility to take a robust approach to slavery and human trafficking and are committed to acting
ethically and with integrity in all our operations and relationships.
We operate in accordance with the International Bill of Human Rights and are committed to implementing
the United Nations Guiding Principles on Business and Human Rights. Our policies are designed to ensure
respect for the dignity and rights of every individual engaged with our business — including direct
employees, agency workers, and individuals within our supply chains.
Policies in Place
To support our commitment to preventing modern slavery, we have implemented a range of policies and
procedures:
Human Rights & Ethics Policy: Sets out our zero-tolerance stance on human rights abuse and
modern slavery. Whistleblowing Policy: Provides a secure mechanism for employees and suppliers to raise concerns
in confidence about unethical or unlawful practices, including human trafficking or forced labour.
Recruitment Policy: Includes robust eligibility to work checks and verification of identification to
protect against illegal labour practices.
Employee Code of Conduct: Reinforces professional behaviour and respect for human rights across
all roles.
Due Diligence Process
To identify and mitigate risk within our operations and supply chains, we:
Conduct due diligence on suppliers, particularly those in high-risk sectors or regions
Require suppliers and contractors to confirm their own compliance with the Modern Slavery Act Monitor labour practices within our organisation to ensure fair treatment and working conditions
Ensure that all employees have a right to work in the UK and are employed directly or through
reputable agencies
We reserve the right to terminate supplier contracts if evidence of modern slavery or related non-
compliance is discovered.
Risk Assessment and Mitigation
We have conducted a risk assessment of our operations and supply chain.
This assessment identified risk
in:
Prioritise working with suppliers who demonstrate transparency and ethical labour practices
Conduct periodic reviews of our supply chain to identify potential risks
Focus on high-risk areas such as outsourced services, uniforms, and cleaning supplies
In response, we are:
Introducing enhanced supplier audits
Increasing staff training on recognising and reporting signs of modern slavery
Monitoring labour practices and payment terms of suppliers with operations outside the UK
Staff Training
We recognise that effective staff training is critical to preventing modern slavery. All employees receive
mandatory modern slavery awareness training as part of their onboarding process, and this training is
refreshed annually for all staff. This training covers:
Identifying signs of modern slavery
Reporting mechanisms
Company policies on ethical working practices
Performance Indicators
To assess the effectiveness of our efforts, we monitor:
The number of concerns or reports related to modern slavery received via our whistleblowing
procedures
Feedback from employees and agency staff
The percentage of suppliers who sign our Modern Slavery Declaration
Results of supplier due diligence reviews
Safeguards and Whistleblowing Support
We encourage openness and honesty. All employees and third parties are encouraged to raise any genuine
concerns in good faith. We guarantee that no one will suffer detrimental treatment for doing so.
Anonymous reports are accepted, though we encourage individuals to provide contact information to
support effective investigation. Malicious or vexatious allegations will be treated seriously and may result
in disciplinary action.
Responsibility for this Statement
Overall responsibility for ensuring this policy is implemented and effective lies with the Managing Director,
supported by senior managers and HR.
Each manager is responsible for ensuring:
Those they supervise are familiar with this policy
Appropriate training is provided
Any suspected breaches are reported and escalated
Policy Owner:
Adejumoke Solaja
Contact Email: [email protected]
Ongoing Review and Effectiveness
We recognise that the risk of modern slavery is dynamic.
We will:
Continue our approach of regular risk assessment and due diligence
Review our supply chain regularly
Audit suppliers as needed based on risk
Update training for new and existing staff annually
Approval and Statement Compliance
This statement was approved by the Board of Directors of Gilead Complete Care Group Limited. It will be
reviewed and updated annually.
Signed:
Adejumoke Solaja
Title: Managing Director
Date: 19th May 2025