MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

1. Introduction

1.1 Bold Cymru is committed to preventing modern slavery and human trafficking in all aspects of our business and supply chains. We recognise our responsibility to uphold human rights and to act with integrity, transparency, and accountability in line with the Modern Slavery Act 2015.

1.2 As a provider of specialist supported living services for adults with learning disabilities, autism, and complex needs, we support vulnerable adults across South Wales. The nature of our work places us in a position of trust and responsibility, and we’re committed to ensuring exploitation, forced labour, servitude, or trafficking has no place within our organisation or the services we deliver.

1.3 This statement sets out the steps we’ve taken to prevent modern slavery in our operations and supply chains.

2. Our Organisation and Structure

2.1 Bold Cymru provides nurse-led, family-owned specialist supported living, enabling adults with complex needs to live safely and independently at Cimla Court and within the wider community.

2.2 We operate within Wales and are regulated by Care Inspectorate Wales (CIW). Our workforce includes support workers, senior support staff, clinical leadership, and management. We work in partnership with local authorities, health boards, and approved suppliers.

3. Our Policies and Governance Framework

3.1 We maintain a governance framework to safeguard against exploitation, including:

• Safeguarding Adults Policy
• Recruitment and Selection Policy
• Whistleblowing Policy
• Code of Conduct
• Supplier and Procurement Standards

3.2 Our safeguarding procedures align with the Social Services and Well-being (Wales) Act 2014 and the All Wales Safeguarding Procedures. Any concerns relating to exploitation, coercion, or abuse are treated as safeguarding matters and reported accordingly.

4. Recruitment and Employment Practices

4.1 Bold Cymru operates robust recruitment and employment processes to ensure all staff are recruited fairly and lawfully. We:

• Conduct safer recruitment, including enhanced DBS checks
• Verify right to work in the UK before employment commences
• Issue written contracts of employment
• Ensure staff are paid at or above the Real Living Wage
• Do not tolerate forced, bonded, or involuntary labour
• Provide access to grievance and whistleblowing procedures without fear of detriment

4.2 We do not charge recruitment fees and do not retain employee identity documents.

5. Supply Chains

5.1 Our supply chain is relatively low risk due to the nature of our services, and primarily includes:

• Recruitment and training providers (including PBM/PBS training delivered via PRT)
• IT and compliance systems
• Property maintenance and facilities contractors
• Office and care equipment suppliers

5.2 We expect all suppliers and contractors to comply with applicable employment and human rights legislation, and seek confirmation where appropriate that suppliers have policies in place to prevent modern slavery.

6. Risk Assessment

6.1 Given the regulated nature of our services and our localised workforce, the risk of modern slavery within our direct employment structure is considered low. However, we recognise that risk can exist within agency labour, extended supply chains, and among the people we support, who may themselves be at risk of exploitation.

6.2 We remain vigilant and ensure safeguarding awareness is embedded across the organisation.

7. Training and Awareness

7.1 Staff receive safeguarding training as part of induction and ongoing professional development, including recognising signs of abuse, exploitation, and coercion.

7.2 Managers are trained to identify indicators of modern slavery, including unexplained control over an individual, lack of personal documentation, signs of coercion or restriction of movement, and financial exploitation.

7.3 Any concerns are escalated in line with safeguarding procedures.

8. Reporting Concerns

8.1 Bold Cymru encourages staff, people we support, families, and partners to report concerns through line management, the Responsible Individual, our Whistleblowing Policy, or local safeguarding authorities.

8.2 All concerns are investigated promptly and, where appropriate, referred to statutory agencies.

9. Continuous Improvement

9.1 We’re committed to reviewing and strengthening our processes annually. Over the coming year we will review supplier assurance processes, reassess risk areas within procurement, and continue safeguarding training and awareness.

10. Approval

10.1 This statement has been approved by the Board of Directors of Bold Cymru and will be reviewed annually.

10.2 Signed: John Doyle
For and on behalf of Bold Cymru
15/07/2026

11. Policy Review

This policy will be reviewed every two years or sooner if there are changes in legislation, regulatory guidance, or internal learning from incidents.

It’s the responsibility of every employee to familiarise themselves with this policy and abide by it. This document is available in alternative language and accessible format.