Section 01
Introduction
This statement is made by We Are Care Ltd (“we”, “us”, “our”) under section 54(1) of the Modern Slavery Act 2015. It sets out the steps we take to ensure that slavery, servitude, forced or compulsory labour and human trafficking are not taking place in our business or supply chains.
We are not currently required by statute to publish a modern slavery statement — our annual turnover is below the £36 million threshold. We publish one voluntarily because we operate in adult social care, a sector where modern slavery and exploitative recruitment carry real and well-documented risk. Transparency on what we do about it is the right standard to hold ourselves to.
Section 02
Our business
We Are Care is a UK workforce partner for social care, headquartered in the UK. We place compliant care workers into regulated care settings — care homes, care groups and specialist providers — and run workforce pathways for new entrants. We operate Baton, our care operating platform, which underpins compliance, rota and onboarding across our workforce operations.
Our workforce is built two ways:
- Trained entrants through our pathways programmes — UK nationals and people with existing right-to-work in the UK
- Experienced carers recruited from the UK market
We do not operate visa-sponsored international recruitment. We do not body-shop. We do not sub-contract recruitment to third parties whose practices we cannot directly verify.
Section 03
Our supply chain
Our supply chain is deliberately narrow. The main categories are:
- Recruitment — direct, in-house. No third-party recruiters used for carer placement.
- Training providers — UK-based, accredited bodies for pre-employment training and ongoing CPD
- Background-check providers — DBS, right-to-work verification, references
- Technology and operational suppliers — UK-based software, payroll and back-office services
- Professional services — solicitors, accountants, insurers
We assess each supplier category for modern slavery risk. The categories with elevated risk profile in our supply chain are recruitment-adjacent services and any sub-contracted labour. Our policy is to keep recruitment in-house specifically to remove this risk surface.
Section 04
Policies
We maintain the following policies, which together address modern slavery risk:
- Anti-Slavery and Human Trafficking Policy — sets out our zero-tolerance position and reporting routes
- Whistleblowing Policy — protects anyone raising concerns about modern slavery, including across our supplier base, without fear of detriment
- Recruitment Policy — defines in-house recruitment standards, right-to-work verification and the prohibition on sub-contracted recruitment
- Safeguarding Policy — covers the wider duty of care to workers and people receiving care
- Supplier Code of Conduct — applied to material suppliers as part of onboarding
These policies are available on request and reviewed monthly through Baton on the first Thursday of each month.
Section 05
Due diligence
Our standard due diligence steps include:
- Right-to-work checks on every carer before any placement — no exceptions
- DBS or equivalent background checks before placement
- Reference verification — minimum two professional references for every carer
- In-person identity verification during onboarding
- Pay verification — every carer paid directly by We Are Care at fair-pay rates; no third-party wage handling, no cash payments, no deductions for accommodation, transport, training or equipment
- Supplier onboarding includes confirmation of compliance with the Modern Slavery Act 2015 for all material suppliers
Section 06
Risk assessment
We continuously assess where modern slavery risk could enter our operation. The areas of focus are:
- Carer recruitment — kept in-house, no third-party recruiters
- International recruitment — we do not operate it; if we expand into sponsored visa routes in future, full risk assessment and policy update will be required first
- Worker fees — we charge no fees to carers under any circumstances; debt bondage is a known modern slavery indicator
- Accommodation tying — we do not provide or arrange accommodation; carers are independent of We Are Care for housing
- Document retention — we do not hold workers’ identity or right-to-work documents beyond the verification period
Section 07
Training
All directors and staff involved in recruitment, onboarding, compliance and provider relationships receive annual training on modern slavery indicators and reporting procedures. New staff complete this training as part of induction. Training content is reviewed and refreshed annually against current Home Office and Independent Anti-Slavery Commissioner guidance.
Section 08
Reporting and effectiveness
We measure effectiveness through:
- Zero-tolerance position maintained — no instances of modern slavery or human trafficking identified in our operations or supply chain to date
- 100% pre-placement DBS and right-to-work verification on every carer placed
- 100% direct payment to carers at fair-pay rates, with no fees charged to workers
- Whistleblowing reports — none received related to modern slavery in the reporting period
Any concerns raised through our whistleblowing channels are investigated and escalated to the appropriate authorities, including the Modern Slavery Helpline (08000 121 700) and, where appropriate, the National Crime Agency and the Police.
Section 09
Approval
This statement was approved by the We Are Care Ltd Board on 1 January 2026.
Signed:
Julian Humphreys
Co-founder & Director
We Are Care Ltd
Date: 1 January 2026