Modern Slavery Policy

Purpose

This policy sets out Moor Mountain Grow’s zero-tolerance position on modern slavery and human trafficking and the steps we take to prevent, identify, and remediate any such practices among volunteers, trainers, contractors, suppliers, partners, and anyone else engaged with our projects.

Scope

This policy applies to all people and organisations working with Moor Mountain Grow, including: volunteers, trainees, contractors, freelance facilitators, paid staff, trustees, partner organisations, and suppliers.

Definitions

• Modern slavery means slavery, servitude, forced or compulsory labour, human trafficking, and any situation where a person is exploited and cannot leave because of threats, coercion, deception, or abuse of power.

• Victim means any person subject to modern slavery or exploitation.

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Commitment and Principles

• Moor Mountain Grow commits to preventing modern slavery in all its forms within our organisation and supply chains.

• We commit to treating anyone who raises concerns or is harmed with dignity, confidentiality, and prompt, appropriate support.

• We require everyone acting for or on behalf of Moor Mountain Grow to comply with this policy and applicable law.

• We will not knowingly engage or continue relationships with individuals or organisations that practice or tolerate modern slavery.

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Roles and Responsibilities

• Trustees and Leadership are responsible for policy approval, resourcing prevention and remediation, and ensuring effective governance and oversight.

• Project Leads and Coordinators are responsible for implementing this policy day-to-day, carrying out checks, and ensuring volunteers and trainers understand expected standards.

• Recruiting Officers are responsible for safe, non-exploitative recruitment processes, verifying identities, and ensuring volunteers and workers are not charged fees.

• All Personnel must follow this policy, complete any required training, report concerns immediately, and cooperate with any investigations.

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Recruitment, Onboarding, and Engagement Standards

• We will carry out right-to-work, identity, and DBS checks as appropriate to role and legal requirements.

• We prohibit charging fees for recruitment to volunteers, trainers, or workers. Any third party that asks recruits to pay fees must be reported and removed as a partner.

• We will provide clear, accessible role descriptions, time commitments, and any remuneration or expenses before engagement begins.

• We will provide accessible information about working conditions, living arrangements (if provided), and complaint routes before any placement starts.

• We will not retain original identity documents as a condition of recruitment or engagement.

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Supplier and Partner Due Diligence

• We will include modern slavery expectations in contracts, partnership agreements, and tender documents.

• We will undertake proportionate due diligence on partners and suppliers, prioritising higher-risk relationships for deeper checks.

• We will require suppliers and partners to confirm compliance with anti-modern slavery standards and to maintain their own policies and remediation processes.

• We will terminate relationships where suppliers or partners fail to remedy confirmed modern slavery risks in a timely manner.

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Training and Awareness

• We will provide mandatory modern slavery awareness training for trustees, staff, project leads, recruiting officers, and frequent volunteers and trainers.

• Training will explain indicators of exploitation, safe and confidential reporting routes, and how to support potential victims.

• We will maintain accessible, plain-language resources for volunteers and partners explaining their rights and how to report concerns.

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Reporting Concerns and Whistleblowing

• Any person who knows or suspects modern slavery must report concerns immediately to a designated safeguarding lead or via our confidential reporting channel.

• Reports will be taken seriously, treated confidentially, and investigated promptly.

• We will protect reporters from retaliation and, where appropriate, allow anonymous reporting.

• We will cooperate with statutory authorities, law enforcement, and specialist victim support services when required.

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Response, Support, and Remediation

• When exploitation is suspected or identified we will:• Prioritise the safety, consent, and wishes of the person affected.

• Provide or arrange appropriate support and emergency assistance, including access to medical care, safe accommodation, legal advice, and specialist support services.

• Escalate to statutory authorities where required by law or when a person is at immediate risk.

• Suspend contractual or volunteering relationships with suspected perpetrators while investigations proceed.

• Document actions taken and lessons learned, and take steps to prevent recurrence.

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Monitoring, Audit, and Continuous Improvement

• We will monitor compliance through periodic reviews, risk assessments, and audit of recruitment and supply-chain practices.

• We will maintain records of due diligence, training completion, reports, investigations, and remediation actions.

• We will review this policy annually or sooner when legal or operational changes require it.

• We will engage volunteers, trainers, and partners in periodic feedback to identify hidden risks and improve safeguards.

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Communication and Accessibility

• This policy will be publicly available on our website and provided in accessible formats to volunteers, trainers, partners, and suppliers.

• We will publish a short, plain-language summary and signpost confidential reporting routes and support options.

• We will ensure policy documents and reporting channels are accessible to people with sensory or cognitive impairments.

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Breaches and Sanctions

• Breaches of this policy may lead to suspension, termination of engagement, contract termination, or referral to enforcement agencies.

• We will take proportionate disciplinary or contractual action against individuals or organisations in breach of this policy.

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Review and Approval

• This policy is approved by Moor Mountain Grow trustees.

• The policy will be reviewed at least annually and updated when necessary to reflect changes in law, best practice, or organisational learning.

• The designated safeguarding lead is responsible for maintaining and publishing the current version.

Contact: 

Safeguarding Lead can be contacted via email on safeguarding@BlindManRoy.com.  This email is also used for whistleblowing needs and is currently monitored by founder Roy Imeson.  

Roy Imeson

Founder of Moor, Mountain, Grow™ and Blind Man Roy™

© 2025 Roy Imeson. All rights reserved