Our commitment

Nomase is committed to preventing modern slavery and human trafficking in our operations and across our supply chains. Modern slavery is a crime and a violation of fundamental human rights. It can take many forms including slavery, servitude, forced or compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We take a zero-tolerance approach to modern slavery within our business and supply chains. We are committed to acting ethically and with integrity in all our dealings and relationships, and to implementing and enforcing effective systems and controls to reduce the risk of modern slavery occurring within Nomase or within any third parties we work with, including agencies and suppliers.

We recognise that victims may not self-identify, and they may present with other concerns. We therefore focus on awareness, safer recruitment, robust reporting routes, supplier due diligence, and continuous improvement through audit and governance processes.

 

Our structure, business and supply chains

Nomase is a UK provider of domiciliary care and supported living services, supporting people with a range of needs including autism, brain injuries, learning disabilities, dementia and mental health challenges. We have delivered social care services for over 10 years and operate under Care Quality Commission (CQC)regulation and quality standards.

Our Catford head office address is Ivy House, Bradgate Road, Catford, London SE64TT, and our CQC Provider ID is 1-1214661759.

Our Chadwell office address is Room 17, Icon Offices 321-323 High Road, Romford, London, RM6 6AX, and our CQC Provider ID is 1-1214661759.

Our Dartford head office address is Office 1.4, 1A Highfield Road, Dartford, DA12AH, and our CQC Provider ID is 1-10233054426.

Our supply chains support the delivery of safe and effective care. They include

  • staffing, including the use of agency workers where appropriate
  • procurement of medical and care-related supplies and consumables
  • facilities maintenance and associated services
  • utilities and IT/communications
  • waste management services.

We work closely with commissioners, local authorities, healthcare professionals, and other stakeholders as part of delivering regulated adult social care services.

 

Policies in relation to slavery and human trafficking

Our commitment is reflected in internal policies and procedures designed to ensure ethical practice, safer recruitment, and effective safeguarding. These include:

  • Modern Slavery and Human Trafficking Policy and Procedure, which sets out our zero-tolerance approach, reporting process, and responsibilities, and is used to underpin our annual statement where required.
  • Raising Concerns, Freedom to Speak Up and Whistleblowing policy, which encourage staff and others to report concerns without fear of reprisal, and enable investigation of wrongdoing including suspected modern slavery.
  • Recruitment  policy, including right to work checks and other safer recruitment measures (supported by our recruitment and onboarding processes), aimed at reducing the risk of employing individuals who may be subject to  exploitation and ensuring legal compliance in employment.

Safeguarding  policies and procedures, aligned with local auhority safeguarding arrangements, to protect people who use services from abuse and exploitation, including modern slavery.

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‍Due diligence processes in our business and supply chains

We take proportionate, risk-based steps to assess and reduce modern slavery risks. Our due diligence approach includes:

Safer recruitment and workforce assurance

  • All staff engaged in providing services are subject to thorough recruitment processes. These include DBS (where applicable), identity checks, employment history, references, and confirmation of validity to work in the UK.
  • We maintain robust checks and remind suppliers and staffing partners that rigorous recruitment controls must not be relaxed during periods of high demand, because that can increase risks of labour exploitation.

Third-party and agency assurance

  • We only use staff provided by third-party organisations (such as agencies) that are registered with the regulator or can confirm that supplied staff are free to work in the UK and meet role requirements.

Supplier onboarding and contracting

  • We conduct due diligence on suppliers before allowing them to become preferred suppliers, including checks (such as online searches) to identify any history of modern slavery offences.
  • We include our modern slavery policy expectations within supplier contracts, and suppliers are required to confirm that no part of their operations contradicts these commitments. We reserve the right to terminate contracts where modern slavery concerns arise.
  • We may ask suppliers to confirm steps they have taken to eradicate modern slavery, and that they hold their own suppliers to account. For UK-based suppliers, we expect at least National Minimum Wage or National Living Wage compliance, safe and fair working conditions, no child labour, and non-excessive working hours, including where overseas supply chains exist.

Audit, monitoring and governance

  • We assess and manage risks through internal auditing processes and governance arrangements, recognising that modern slavery risk is not static and requires ongoing review.
  • We review effectiveness regularly and intend to take further steps to identify, assess and monitor potential risk areas, particularly in our supply chains, and to ensure staff have access to training and guidance on recognising and responding to modern slavery concerns.

 

Risk areas and how we assess and manage risk

We recognise that modern slavery risks can occur in any sector, including health and social care. Based on our operations and supply chain profile, we consider the following areas to present relatively higher risk:

Agency staffing and labour supply
Recruitment and labour supply can carry increased risk, particularly where third parties are involved and where there is pressure to fill shifts quickly. We mitigate this risk by using only appropriately assured agencies and by requiring confirmation of right to work and role suitability for supplied staff.

Procurement of goods from higher-risk regions
Some goods may be manufactured in regions or sectors associated with higher modern slavery prevalence. We mitigate by supplier risk assessments, onboarding checks, modern slavery clauses in contracts, and ongoing monitoring and review through audit activity.

Wider supply chain services
Facilities maintenance, utilities, consumables, and waste management may involve subcontracting and layered supply chains. We address this by conducting supplier due diligence, requiring alignment to our standards, and considering modern slavery risk as part of supplier review and contract management activity.

 

How we assess risk
We undertake risk assessments of how suppliers are operating to help identify where modern slavery or human trafficking risks may arise, using appropriate templates and tools available within our management systems where applicable.

We also keep our approach under review, including considering how changes in operating models or fluctuations in demand may lead to new or increased risks of labour exploitation.

 

Effectiveness and performance indicators

We measure effectiveness in ensuring slavery and human trafficking are not taking place through a set of proportionate indicators and oversight activity.

These include:

  • Incident and concern reporting: Monitoring the number of reports and incidents related to modern slavery within our organisation and supply chains, including concerns raised internally or externally.
  • Audit and  assurance activity: Regular audits and inspections to ensure compliance with our policies and contractual expectations, and to identify  improvements needed in our controls and processes.
  • Supplier compliance checks: Tracking the number of suppliers onboarded with modern slavery clauses, and the number of suppliers reviewed or audited (where appropriate to risk).
  • Training completion and competence: Tracking the number of staff trained in modern slavery awareness and refresher training, and using supervision and engagement to confirm understanding and confidence in  reporting routes.
  • Stakeholder  feedback:  Reviewing feedback from employees, people we support, and stakeholders to identify areas for improvement in our safeguarding and reporting systems.

Aspart of our ongoing monitoring, we look for assurance signals such as whetherany reports are received from employees, the public, or law enforcement orsafeguarding teams indicating modern slavery practices have been identified.
In the previous reporting period, Nomase Supported reported that no reports hadbeen received in its 10+ years of operation to indicate modern slaverypractices had been identified, and we continue to treat this as somethingrequiring active vigilance rather than complacency.

 

Training and capacity building

Training and awareness are essential to early identification and effective response. We provide:

  • induction training for all new employees on recognising signs of modern slavery and how to report concerns
  • ongoing training and refreshers to keep staff informed about developing risks and best practice
  • role-appropriate training covering indicators of modern slavery and human trafficking, and what to do if a disclosure is made or suspected, including escalation to the Registered Manager or police if there is immediate danger
  • support for staff who may be subject to slavery or trafficking, or who raise concerns in good faith, with protections against detrimental treatment for  raising genuine concerns

 

Reporting concerns and escalation routes

We encourage staff, people we support, families, professionals, and members of the public to raise concerns. Our reporting process reflects safeguarding duties and regulatory expectations:

  1. Where a concern is identified, staff must remember that victims may not self-identify and may present with another issue.
  2. If an individual or group is at immediate risk of danger or harm, the police must be contacted on 999.
  3. Staff must discuss the concern with their line manager (where appropriate) and escalate to the Registered Manager without delay.
  4. The concern is escalated to the local authority safeguarding team (Lewisham Council Safeguarding Adults Team) to safeguard the individual from harm and help prevent future occurrences.
  5. Where required, a notification is made to the CQC via the provider portal.

We also accept and take seriously concerns raised anonymously, although we recognise anonymity can make investigation more difficult, and we encourage individuals to identify themselves where they feel safe to do so.

 

Approval and publication

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps Nomase to ensure that slavery and human trafficking are not taking place in our business or supply chains. The statement will be reviewed and updated annually and published on our website in line with transparency expectations, with approval by senior leadership and sign-off by a Director.

 

Contact

To report a concern or request further information, please contact:
Email: info@nomase.co.uk | Telephone:0203 750 9722

Approved by: Senior Management Team / Board of Directors, Nomase
Signed: Victor Isibor, Managing Director (Director)
Date: 05/01/2026