Modern Slavery and Human Trafficking Statement
Care built on freedom, fairness and dignity
How Lifetouch Care prevents modern slavery and human trafficking in our services, our recruitment and our supply chain.
Our commitments
- Zero toleranceNo modern slavery or trafficking anywhere in our business or supply chain.
- Fair, direct employmentWritten contracts, at least the National Living Wage, paid travel time.
- No fees, no held documentsWe never charge recruitment fees or keep staff passports.
- Every concern acted onConfidential reporting, safeguarding referral and the national helpline.
Contents
Lifetouch Care does not tolerate modern slavery or human trafficking in any part of its business or supply chain.
Introduction
Lifetouch Ltd, trading as Lifetouch Care, does not tolerate modern slavery or human trafficking in any part of its business or supply chain. This statement sets out the steps we have taken, and will take, to prevent it.
Our annual turnover is below the £36 million threshold in section 54 of the Modern Slavery Act 2015, so we are not legally required to publish a statement. We publish this one voluntarily because the people we support, our staff and our commissioners deserve the same transparency from a small provider as from a large one.
This statement covers the 2026 financial year and will be reviewed and republished every year.
Our organisation
Lifetouch Care is a nurse-led home-care provider based in Wolverhampton, West Midlands, registered with the Care Quality Commission (CQC) since 24 March 2025.
Complex care
Nurse-led support including tracheostomy and ventilator care, PEG/NG feeding, spinal and acquired brain injury, and end-of-life care.
Domiciliary care
Personal care, medication support, meals, mobility and companionship.
Supported living
24-hour packages focused on independence and community inclusion.
Community support
Daily living skills, social inclusion, travel assistance and respite.
We deliver care for NHS and local authority commissioners, including the Staffordshire ICB Home Care and Complex Care Framework and West Midlands local authority packages, as well as for private clients.
Our workforce is made up of NMC-registered nurses and care workers employed directly by Lifetouch Ltd.
Our supply chains
Our supply chain is small and mostly UK-based. Our main exposure is in the goods we buy, not the care we deliver.
| Category | Examples | Risk level |
|---|---|---|
| Personal protective equipment | Gloves, aprons, masks. Global manufacturing with known forced-labour concerns. | Higher |
| Clinical consumables | Feeding, catheter, stoma and suction supplies | Medium |
| Uniforms | Staff tunics and workwear. Textile supply chains. | Medium |
| Technology and software | Care management system, IT hardware | Low to medium |
| Professional services | Training providers, insurance, accountancy, DBS checks | Low |
| Office and facilities | Stationery, cleaning, utilities | Low |
We aim to staff all care with our own directly employed workers and to avoid agency staff. If we ever need an agency, we use only established, reputable agencies and confirm that they carry out right-to-work checks, pay at least the National Living Wage and charge workers no fees.
Our policies
The following policies set out how we prevent, detect and respond to modern slavery:
- Anti-Slavery and Human Trafficking Policy. Our zero-tolerance commitment and how concerns are handled.
- Safeguarding Adults and Children Policy. Recognises modern slavery as a category of abuse under the Care Act 2014 and follows local authority safeguarding procedures.
- Recruitment and Selection Policy. Right-to-work, identity and DBS checks for every worker.
- Whistleblowing (Speak Up) Policy. Lets staff raise concerns confidentially without fear of reprisal.
- Equality, Diversity and Inclusion Policy. Fair and lawful treatment of every employee.
- Sustainable procurement. Supplier checks covering ethical and environmental standards.
All policies are reviewed at least every year by the directors.
Due diligence and recruitment
Ethical recruitment is our most important control, because exploitation in social care most often happens through recruitment and employment practices.
Recruiting our staff
- Every worker is employed directly on a written contract, at or above the National Living Wage, with paid travel time between visits.
- Right-to-work and identity checks are completed in person against original documents before anyone starts.
- Every worker has an enhanced DBS check and verified references.
- We never charge recruitment fees and never hold staff passports or identity documents.
- We check for warning signs such as shared bank accounts, shared addresses across unrelated applicants, or a third party speaking for a candidate.
- Payroll is run in-house by a director, so we can spot irregular payments.
Suppliers
- We buy clinical supplies and PPE from established UK distributors and NHS-approved routes where possible.
- New suppliers are asked to confirm their own approach to modern slavery before we place regular orders.
Risk assessment
Our highest risks are in recruitment and in PPE sourcing. We review them every year and whenever our services change.
| Area | Risk | How we manage it |
|---|---|---|
| Recruitment | Workers placed through exploitative third parties or charged fees | Direct employment, in-person checks, no-fee policy, agency use avoided |
| Pay and conditions | Underpayment through unpaid travel time or deductions | Travel time between visits is paid; in-house payroll and National Living Wage audits |
| PPE and consumables | Forced labour in overseas manufacturing | UK distributors, supplier assurance |
| People we support | Adults at risk being exploited by others | Safeguarding training, care-visit observation, referral to the local authority |
Because our staff work in people’s homes and the community, they are also well placed to spot signs of exploitation affecting the people we support and their households.
Training and awareness
Every member of staff learns to recognise and report modern slavery, as part of mandatory safeguarding training at induction and at each annual refresher.
- Directors and nurses who lead care packages receive more detailed training on spotting exploitation and making referrals.
- Staff who recruit are trained on right-to-work checks and recruitment warning signs.
- Supervision visits and team meetings are used to reinforce awareness and share learning.
- This statement and our policy are shared with all staff and are available on request.
Reporting concerns
Anyone can raise a concern about modern slavery, and we will act on it promptly and confidentially.
- Staff report to the Registered Manager or Nominated Individual, or through our whistleblowing procedure.
- Concerns about a person we support are handled as a safeguarding matter and referred to the local authority safeguarding team.
Measuring effectiveness
We will track the measures below and report results in next year’s statement.
| Measure | Target |
|---|---|
| Staff completing modern slavery awareness training | 100% within 3 months of starting |
| New starters with right-to-work, ID and DBS checks completed before first shift | 100% |
| Staff paid at or above the National Living Wage (payroll audit) | 100%, checked quarterly |
| Regular suppliers confirming their modern slavery approach | All by year end |
| Concerns raised, and share investigated within 5 working days | Reported annually; 100% investigated |
Approval
This statement was approved by the directors of Lifetouch Ltd.
