Effective Date: 1st July 2024
Last Updated: 1st July 2024

Company: Obsidian Homecare Services Ltd, trading as Obsidian Healthcare Recruitment
Registered in the Republic of Ireland
CRO No.: 768132
Registered Office: 3rd Floor, 40 Mespil Road, Dublin 4, Ireland, D04 C2N4

1. Introduction
1.1 Obsidian Homecare Services Ltd, trading as Obsidian Healthcare Recruitment (hereafter referred to as "Obsidian Healthcare"), is committed to ensuring that modern slavery, human trafficking, and all forms of forced labour have no place within our operations, supply chains, or business relationships in Ireland. This policy applies to all employees, contractors, agency staff, suppliers, and any other parties engaged by Obsidian Healthcare in the Republic of Ireland.

1.2 Modern slavery, for the purposes of this policy, encompasses slavery, servitude, forced or compulsory labour, human trafficking, and the exploitation of individuals for personal or commercial gain. Obsidian Healthcare expressly prohibits such practices in any form.

1.3 This policy has been developed to comply with the Irish Criminal Law (Human Trafficking) Act 2008–2013 and all other applicable Irish labour and human rights legislation.

2. Scope
2.1 This policy applies to:
2.1.1 All employees and workers engaged directly by Obsidian Healthcare in Ireland.
2.1.2 All candidates, contractors, and agency staff supplied through our recruitment services.
2.1.3 All suppliers, subcontractors, and business partners engaged to provide goods or services to Obsidian Healthcare.
2.1.4 Any joint ventures, partnerships, or other commercial arrangements in which Obsidian Healthcare holds a controlling interest.

2.2 All individuals and entities covered under this policy are expected to comply fully with its requirements, and adherence is considered a condition of engagement or contractual relationship.

3. Our Commitment
3.1 Obsidian Healthcare is committed to preventing modern slavery in all forms and ensuring that:
3.1.1 All employment practices adhere to Irish employment legislation, including fair wages, working hours, and conditions.
3.1.2 No employee, contractor, or candidate is subject to forced labour, bonded labour, or coercion in any part of our operations.
3.1.3 Recruitment and vetting procedures are designed to detect and prevent exploitation or trafficking, including the verification of identity, qualifications, and lawful right to work in Ireland.
3.1.4 Suppliers and business partners are expected to adhere to similar standards of anti-slavery and ethical conduct. Obsidian Healthcare reserves the right to terminate contracts or relationships if violations are discovered.

4. Due Diligence and Risk Assessment
4.1 Obsidian Healthcare conducts regular due diligence to identify, assess, and mitigate risks of modern slavery within its operations and supply chains, including:
4.1.1 Evaluating potential suppliers and service providers prior to engagement.
4.1.2 Requesting evidence of compliance with employment, labour, and anti-slavery laws from suppliers.
4.1.3 Monitoring high-risk areas, including sectors or roles where temporary staffing may be susceptible to exploitation.
4.1.4 Conducting periodic audits and inspections to ensure ongoing compliance with this policy.

5. Recruitment and Employment Practices
5.1 Obsidian Healthcare implements strict procedures for the recruitment and placement of healthcare professionals to prevent exploitation, including:
5.1.1 Verification of identification, eligibility to work in Ireland, and professional registration.
5.1.2 Garda vetting and reference verification prior to placement.
5.1.3 Ensuring that no fees or costs associated with recruitment are borne by candidates for permanent or temporary placements.
5.1.4 Providing all workers with clear written contracts outlining employment terms, rights, and responsibilities.

6. Supplier and Partner Compliance
6.1 Obsidian Healthcare expects all suppliers, subcontractors, and business partners to comply with the Modern Slavery Act and ethical employment standards.
6.2 Contracts and agreements include clauses requiring suppliers to confirm that:
6.2.1 No forced labour, human trafficking, or slavery is involved in the production of goods or provision of services.
6.2.2 Employment conditions for all workers meet legal standards for working hours, pay, and health and safety.
6.2.3 Policies and procedures are in place to detect and prevent exploitation within their operations.

7. Training and Awareness
7.1 Obsidian Healthcare provides regular training and guidance to all staff involved in recruitment, compliance, and supplier management to ensure awareness of modern slavery risks and reporting mechanisms.
7.2 Staff are encouraged to report concerns regarding slavery, trafficking, or exploitation without fear of reprisal.

8. Reporting and Whistleblowing
8.1 Employees, candidates, suppliers, or other stakeholders who become aware of suspected modern slavery, human trafficking, or exploitation are encouraged to report concerns immediately.
8.2 Reports may be made directly to Obsidian Healthcare’s management team, the Data Protection Officer, or anonymously via designated reporting channels.
8.3 Obsidian Healthcare will investigate all reported concerns promptly, confidentially, and in compliance with Irish law. Retaliation against any individual making a report in good faith is strictly prohibited.

9. Monitoring and Review
9.1 This policy is reviewed annually or more frequently as necessary to ensure its effectiveness.
9.2 Any breaches, incidents, or potential risks of modern slavery identified within our operations or supply chains will trigger an immediate review and corrective action.
9.3 Senior management is responsible for the ongoing implementation, monitoring, and improvement of this policy.

10. Governance and Accountability
10.1 Ultimate accountability for the prevention of modern slavery rests with Obsidian Healthcare’s Board of Directors and senior management team.
10.2 The Data Protection Officer and Compliance Officer are responsible for oversight of training, reporting mechanisms, audits, and supplier assessments relating to modern slavery risks.
10.3 Non-compliance by any employee, supplier, or contractor may result in disciplinary action, contract termination, or other legal remedies as appropriate.

11. Communication
11.1 This Modern Slavery Act Policy is publicly available on the Obsidian Healthcare website.
11.2 All employees, candidates, and suppliers are provided access to this policy and are required to acknowledge their understanding and acceptance.
11.3 Updates and amendments to this policy will be communicated promptly to all relevant parties.

12. Contact Details
12.1 For queries, concerns, or reports regarding this policy, contact:

Obsidian Homecare Services Ltd
Trading as Obsidian Healthcare Recruitment
3rd Floor, 40 Mespil Road, Dublin 4, Ireland, D04 C2N4
Email: gdpr@obsidianhealthcare.ie
Telephone: +353 (0)1 902 6767

13. Approval and Review
13.1 This policy has been approved by the Board of Directors of Obsidian Homecare Services Ltd and is effective as of 2nd October 2025.
13.2 The policy will be reviewed at least annually or sooner if required due to changes in law, regulation, or operational requirements.