Modern slavery remains a significant issue in the UK care sector, particularly in workforce recruitment. With the growing demand for care workers, care homes must ensure that their hiring practices are ethical and legally compliant. Failing to address modern slavery risks can result in legal action, reputational damage, and the exploitation of vulnerable workers.
This guide outlines the risks of modern slavery in care home recruitment, key compliance requirements for employers, and best practices for ethical recruitment.
Understanding Modern Slavery in the Care Sector
Modern slavery in care home recruitment can take different forms, including:
- Debt Bondage – Workers are forced to repay excessive recruitment fees, trapping them in unfair working conditions.
- Forced Labour – Employees work under coercion or threats, often with little or no pay.
- Exploitation of Migrant Workers – Some employers or agencies withhold wages, passports, or visas.
- False Promises – Workers are misled about job conditions, salary, or housing before arriving in the UK.
The UK Home Office and Care Quality Commission (CQC) enforce strict regulations to prevent modern slavery in care recruitment. Care homes must ensure all recruitment channels are ethical and transparent.
Key Risks for Care Homes Hiring International Workers
Unregulated Recruitment Agencies
Many care homes rely on third-party recruitment agencies to hire overseas staff. However, some agencies engage in unethical practices, such as:
- Charging excessive recruitment fees to candidates
- Falsifying job offers or contract terms
- Exploiting visa sponsorship as leverage to control workers
Solution: Only work with Home Office-licensed and ethical recruitment agencies that do not charge workers illegal fees.
False Job Advertisements and Misleading Contracts
Some workers arrive in the UK under false expectations of salary, job duties, or working hours. Employers may unknowingly hire staff through fraudulent recruitment schemes.
Solution: Clearly outline salary, working conditions, and visa terms in a signed contract before employment begins. Ensure contracts match the Skilled Worker visa salary threshold.
Retention of Documents and Restricted Movement
Some unethical employers or agencies confiscate workers’ passports or visas, limiting their ability to leave employment.
Solution: Ensure all employees retain full control of their personal documents and have the freedom to change employers if needed.
Poor Accommodation and Deductions from Wages
Some care workers are housed in substandard conditions, with excessive deductions taken from their wages for accommodation or travel costs.
Solution: If providing accommodation, ensure it meets UK housing standards and is not a condition of employment.
Legal Requirements for Care Home Employers
Compliance with the UK Modern Slavery Act 2015
The Modern Slavery Act 2015 requires employers to prevent exploitation in their workforce. Care homes must:
- Conduct due diligence on recruitment agencies
- Ensure contracts are fair and legally compliant
- Train HR staff to recognize modern slavery risks
Sponsor Licence Compliance for Skilled Worker Visa Holders
Care homes employing migrant workers under the Skilled Worker visa must:
- Provide genuine job roles that meet salary requirements
- Conduct Right to Work checks to prevent illegal employment
- Report any breaches of sponsorship duties to the Home Office
Read more: How to Apply for a Sponsor Licence for Care Homes
Ethical Recruitment Code of Conduct
Care homes must follow the Code of Practice for the International Recruitment of Health and Social Care Personnel in England. Key requirements include:
- No recruitment fees charged to workers
- Transparency in employment terms
- Freedom to leave employment without penalties
Best Practices to Prevent Modern Slavery in Recruitment
Work Only with Ethical Recruitment Agencies
- Verify that agencies do not charge workers illegal recruitment fees
- Ensure agencies are Home Office-compliant
- Request written agreements detailing ethical recruitment policies
Conduct Thorough Right to Work Checks
- Verify passports, visas, and work permits before hiring
- Maintain compliance with Home Office right-to-work guidance
- Avoid hiring undocumented workers or those on fraudulent visas
Read more: Right to Work Checks for Care Homes
Offer Transparent Contracts and Fair Wages
- Ensure workers understand their rights before signing contracts
- Pay at least the Skilled Worker visa salary threshold (£23,200 per year, increasing to £25,000 in April 2025)
- Provide clear grievance procedures for reporting unfair treatment
Provide Ethical Working Conditions
- Offer safe and legal accommodation options
- Allow workers full freedom of movement without employer restrictions
- Ensure regular breaks and paid overtime in line with employment laws
Train Staff on Recognizing Modern Slavery
- Educate HR teams and managers on signs of worker exploitation
- Encourage employees to report concerns anonymously
- Conduct internal audits to ensure compliance with modern slavery laws
How Borderless Can Help Care Homes Ensure Ethical Recruitment
Navigating modern slavery risks in recruitment can be complex. Borderless helps care homes:
- Verify ethical recruitment agencies to ensure compliance
- Assist with sponsor licence applications and Skilled Worker visa sponsorship
- Ensure fair employment contracts that meet UK legal standards
- Provide compliance training for HR teams
For expert guidance on ethical recruitment and sponsor licence compliance, contact Borderless today.
Conclusion
Modern slavery risks in care home recruitment can be mitigated through ethical hiring practices, strong compliance measures, and proactive due diligence. Employers must take responsibility for ensuring that workers are treated fairly and legally throughout the recruitment process.
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