Modern Slavery and Human Trafficking Statement



This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1st April 2021 to 31st March 2022.

The statement sets down Social Heart CIC commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small.  Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Social Heart CIC which are as follows:

Social Heart Community Interest Company (CIC) is a Limited Company by Guarantee, registered in England and Wales, company number 09454095.

Founder Director: Nicky Kent

Non-Executive Directors: Dr Judith Wester and Richard Jefferies.

Social Heart CIC offers a range of in person and online business support services, for example: business consultancy, advice, coaching and mentoring, specialising in Social Enterprise. All surpluses are reinvested to support beneficiaries who are furthest away from the employment market, for example those living with life limiting or disabling health conditions and/or difficult life circumstances.

Supply chain management includes:


Programme and business goal setting, identifying business and client needs through community engagement and forming appropriate business strategies; reviewing resources and lifecycle; identifying trustworthy software and online tools; operational management; risk management; developing training materials and resources; identifying staffing needs, recruitment, training and development; procurement processes, quotes and necessary supplier references within a buy local, buy Shropshire context.


Working/collaborating with reliable partners and stakeholders, for example local authorities, social enterprises, charities and statutory organisations, funding/tender lead bodies, individuals, and community groups.

Set Up:

Develop bespoke and core business support programmes; provide networking, events, discussion and feedback opportunities for all sources; provide Ecommerce, financial and payment facilities with trustworthy, reliable and recognised suppliers; customer focus system and processes that meet customer /beneficiary needs.


1-1 or group advice, support, coaching sessions, workshops, training, peer to peer support and networking, online and in person where appropriate.

Monitoring and Evaluation:

Check progress against plans through monitoring and evaluation and  produce valuable social value evidence, by assessing the impact, outputs and outcomes of the business and support programmes, for example, conduct surveys, develop case studies, testimonials and formal reviews

The Company currently operates in the following countries:

United Kingdom

The following is the process by which the Company assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking. Social Heart CIC will risk assess as follows:

  • Will Social Heart CIC use unskilled, temporary and/or seasonal workers?
  • Will Social Heart CIC be employing foreign workers/temporary staff employed under temporary contracts who are engaged by foreign or English temporary staffing agencies?
  • Will Social Heart CIC use subcontractors (possibly with several links in the supply chain), temporary staffing agencies and short-term seasonal contracts?
  • Will there be job functions which are outsourced and carried out by foreign workers/ temporary staff who are not immediately visible or noticeable because the work is carried out at night or in remote places or under lone working conditions?
  • Will Social Heart CIC work collaboratively or in partnership within a business sector which has previously been affected by undeclared labour, social dumping, illegal labour and human trafficking?

General Precautions include:

Social Heart CIC:

  • will be aware of human trafficking for forced labour and the applicable legislation
  • will draw up guidelines against human trafficking and hidden forced labour
  • will consider including the points below in the company’s general guidelines:
      • Obligation to combat forced labour in the company in connection with direct employments and when using subcontractors
      • Guarantee that the employees have freedom of movement and are free to enter into and terminate employment
      • Regular risk assessment and monitoring of working conditions among employees and at subcontractors
      • Clear procedures for follow-up, including regular random checks of working conditions and subcontractorsProcedures for action and consequence in the event of signs of forced labour
  • guidelines on prevention of forced labour and status within this area will be included where appropriate in the CIC 34 annual report/status report
  • will know which groups of workers/temporary staff are most likely to be exploited and which circumstances render workers/temporary staff vulnerable to exploitation
  • will collaborate with authorities, trade associations and trade unions on identifying and reporting possible cases of human trafficking for forced labour
  • will notify partners in the supply chain of the risk of human trafficking for forced labour
  • managers will talk to the workers regularly and informally to hear about their working conditions and any critical conditions

High Risk Activities

The following Social Heart CIC activities are considered to be at high risk of modern slavery or human trafficking:

  • Vulnerable adults and young people
  • Minority and social excluded groups
  • Those lone and remote working

Responsibility for the Company’s anti-slavery initiatives is as follows:

  • Policies: Founder Director is responsible for creating and reviewing policies. The process by which policies are developed is looking at best practice and Gov.UK guidelines and adapting to the needs of the company.
  • Risk assessments: Founder Director is responsible for risk assessments in respect of human rights and modern slavery.
  • Due diligence: Founder Director is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.


To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to undertake online training course relating to human trafficking and modern slavery on starting employment, during the induction process.


The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

  • Whistleblowing policy – the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
  • Employee / Volunteer Handbooks – The Employee and Volunteer Handbooks set down the actions and behaviour expected of employees and volunteers when representing the Company.
  • Company Social Responsibility (CSR) Policy – The Company’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.

 Due Diligence Processes for Slavery and Human Trafficking

Social Heart CIC undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners and/or evaluating the modern slavery and human trafficking risks of each new supplier and/or invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Performance indicators

The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including for example, requiring all staff to have completed online training on modern slavery within induction training process, formal review and appraisals and by analysing monitoring and evaluation processes and data.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. Board of Directors endorses this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by:



Nicola Kent



Founder Director and Operational Manager


Date: 1/4/2021


Signature:  N J Kent