Modern Slavery Act

Modern Slavery Statement 

Keys Group Limited 

Company number 14101282 

Introduction  

This statement is published in accordance with the Modern Slavery Act 2015.  It sets out the steps that Keys Group Limited and each of its subsidiaries (together “Keys Group”) has taken to ensure that slavery and human trafficking is not taking place in any part of our business or our supply chains. 

Organisation's structure 

Each subsidiary company in Keys Group is listed in the Appendix and the ultimate parent as at 31 March 2024 is Keys Group Limited which has its registered office at Maybrook House, Third Floor, Queensway, Halesowen, West Midlands. Keys Group operates in both England and Wales and has over6500 employees.  We currently provide specialist support to more than 2079 young people, adults and families across all our services in England and Wales. 

Our business  

Keys Group is a leading provider of care and support and we operate under three distinct brands: 

Our businesses are regulated by a number of regulators including Ofsted, CQC and Care Inspectorate Wales.  As such we are required to meet compliance with regulatory standards and are regularly inspected against these. 

The ethos of Keys Group is simple. We inspire, encourage and support children, young people and adults to achieve great things and lead happy, healthy and successful lives. 

Our core values 

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our anti-slavery and human trafficking policy reflects our commitment to acting ethically and with integrity in all our business relationships.  

Both modern slavery and human trafficking are incompatible with our core values. Our “EPIC” core values are: 

These values underpin the whole ethos of Keys Group and our aim is to embed these core values in every aspect of our business including in our approach and handling of modern slavery and human trafficking. 

Our policies relating to slavery and human trafficking 

We acknowledge that modern slavery often takes place in the course of employment however the vulnerable people we support may also be exposed to modern slavery, human trafficking and (in the case of young people) child sexual exploitation and criminal exploitation.  As a responsible provider we have a number of polices that are relevant (either directly or non-directly) to modern slavery, human trafficking and/or child exploitation: 

All our employees are required to comply with these polices in the course of their employment and where appropriate receive training on them. 

Our supply chains 

Our supply chains include:  

Most procured goods and services are procured by one central management company in order to allow greater oversight and scrutiny of our supply chain.  

A significant amount of goods such as food and household goods are sourced and purchased locally from commercial retail outlets and are therefore not procured centrally. 

Due diligence processes for slavery and human trafficking 

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.  We do this by: 

We expect all those who we deal with on a professional level to comply with our values and we will be requesting that our suppliers have a suitable statement that mirrors Keys Group. 

We also have in place systems to: 

We use a centralised agency staff procurement process to further enhance our stringent assurance checks for agency staff including right to work and advanced DBS checks.  Only agency suppliers capable of evidencing agency staff compliance with these stringent requirements are added to the agency system as a potential provider of services to Keys Group. 

Training 

All our operational staff are required to undertake mandatory training in relation to safeguarding, whistleblowing, sexual exploitation and criminal exploitation. Our exploitation specialist adviser also offers bespoke consultations to individual services where there is an identified need or risk factors are escalating. This package includes tailored preventative interventions for individual young people that suit specific learning outcomes in line with local authority’s expectations. All consultations include the voice and influence of young people to achieve best practice and uptake of engagement in proactive strategies to keep young people safe and promote healthy relationships.  

Environmental Social and Governance (ESG) 

Keys Group have an established ESG strategy that includes compliance with modern slavery principles.  We revised our ESG objectives at the start of 2023 and delivered significantly against all of our objectives. Additionally, our ESG KPIs are tested quarterly to monitor performance. 

Group Safeguarding and Participation Director 

Keys Group firmly believes that the safeguarding of the people it supports is everyone’s responsibility. Our Safeguarding and Participation Director oversees our strategy and chairs the Safeguarding Committee. The committee steers good practice throughout the whole organisation and encompasses wide representation from across our businesses.  

Our participation strategy is developing not only to recognise and celebrate the varied localised initiatives throughout the businesses but to harness the enthusiasm of interested parties in making sure the voice of all the children, young people and adults we support is listened to, heard and acted upon in true partnership. The strategy and accompanying framework is developing to cater for the increasingly diverse needs across the business. Opportunities for collaboration with community projects are being further explored, which is providing a gateway to community involvement and strengthening relationships and external networks. 

IT Support 

We have IT systems in place to ensure that internet activity is strictly filtered to remove as much harmful material as possible and to give the people we support a safe internet experience.  We continue to review and invest in our IT systems to ensure that they provide a safe and secure means for young people to access the internet. 

All our childrens services are encouraged where appropriate to develop social media and mobile phone contracts to go hand in hand with a range of pre-approved guardian apps.  

Specialist Support 

We have a dedicated specialist support team of advisers to provide training, support and consultation to our services and where required to work directly with young people.  

The areas of specialist knowledge covered include: 

The exploitation adviser has developed and implemented a framework with a set of processes which help our childrens residential /education and supported accommodation services to understand the nature of trafficking, modern slavery and exploitation and to formulate care and education plans, that effectively respond to the complex contextual elements that are so often linked to exploitation through modern slavery.  The approaches being followed underpins national standards and best practice models around human trafficking and modern slavery and has been extremely effective in supporting the safeguarding of complex young people with high levels of risk due to exploitation and the approaches provide intervention for those with emerging vulnerability factors and peripheral risks.  

The police liaison advisor has been a founding member and integral part of a small working group, led by the National Police Chief’s Council (NPCC) lead for missing young people.  This group has formulated the Children Missing from Care Framework, which provides clear national guidance to care providers, police, local authorities and others about how absence and missing should be responded to.  The framework was formally launched at the National Missing Person Conference on 25 May 2023, coinciding also with National Missing Children’s Day.  Keys Group has already adopted and applied the principles set out in the framework, resulting in more effective multi-agency responses to absence and missing, including occasions where young people are or may be victims of modern slavery and/or exploitation. 

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