We are committed to acting responsibly and upholding our high ethical standards. We have a zero-tolerance approach towards any form of modern slavery and human trafficking and we expect our suppliers to subscribe to a similar principle.
The steps we have taken during the current financial year in relation to combating modern slavery and human trafficking are as follows:
In relation to our supply chains, which include the sourcing of all products and services necessary for the provision of high quality health care to our patients:
- We expect and require all of our suppliers to comply with all local, national and (where applicable) international laws and regulations.
- Our point of contact is preferably with a UK or EU company, who may also be required to comply with the requirements of the Act or similar legislation in other EU states.
- Most of our purchases are against existing supply contracts or frameworks which have been negotiated under the NHS Standard Terms and Conditions of Contract which have the requirement for suppliers to have suitable anti-slavery and human trafficking policies and processes to be in place.
- We expect each entity in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain, as it is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain.
- We expect all those in our supply chain and contractors to comply with our values.
- We will not support or deal with any business knowingly involved in modern slavery and human trafficking. All suspicions of modern slavery and human trafficking will be reported to the relevant authority.
- We will consider modern slavery issues when making procurement decisions.
In relation to due diligence and risk management (other than our supply chains):
- We undertake appropriate pre‐employment checks and require our agencies on approved frameworks to do the same.
- We protect staff from poor treatment and/or exploitation, and comply with all respective laws and regulations including fair pay rates and terms of conditions of employment.
- We consult and negotiate with Trade Unions on proposed changes to employment, work organisation, and contractual relations.
In relation to our policies and procedures, which set the tone for how we as an organisation operate:
- We have a clear Whistleblowing Policy that applies to all individuals working for our Trust and is published on our intranet site. If there are any genuine concerns about any wrongdoing or breaches of the law, including modern slavery laws, these concerns can be raised in confidence and without fear of disciplinary action.
In relation to the training of our staff:
- Our training for staff includes how to recognise and respond to indicators of human rights abuses. It includes examples of red flags specific to our industry, explain our reporting procedures for suspicions and promote an organisation wide sense of responsibility.
- We have teams responsible for safeguarding of adults and children, to whom staff are responsible for reporting of concerns and whom train staff on how to recognise issues of concern.
This statement will be reviewed annually. This statement was approved by our board of directors in May 2018.