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Modern slavery policy

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Introduction

This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, sets out HBSUK’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 2021/2022.

As part of the healthcare sector, HBSUK recognises that it has a responsibility to take a robust approach to slavery and human trafficking. HBSUK is absolutely committed to preventing slavery and human trafficking in its corporate activities, and ensuring that those in its supply chains, and contractors, are free from slavery and human trafficking and comply with our values.

 

Organisational Structure and Supply Chains

HBSUK is a provider of virtual and face to face surgical, triage and outpatient services to insurers, corporate businesses, the NHS, and private patients, on a nationwide basis. HBSUK’s head office is in Nottingham but operates across the UK, in England and Wales.

HBSUK’s supply chain mainly comprises doctors, nurses, and allied health professionals, as individuals or part of groups, providing medical treatments and assessments. Our supply chain also comprises suppliers as expected in the running of business such as facility providers, therapy providers, IT providers, recruitment providers, management consultants and professional services.

HBSUK predominantly operates in the UK, with a small supply associated with the international recruitment of nurses. HBSUK has an annual turnover in excess of £7m.

Risk Assessment Process

On an annual basis, HBSUK evaluates the business risks, comprising country risks, sector risks, transaction risks and business partnerships, to determine whether or not particular activities or countries are high risk in relation to slavery or human trafficking. Any risks identified from the above process will be prioritised and dealt with in accordance with the due diligence section below.

 

High-Risk Activities

HBSUK does not believe it has any particular activities or is involved with any countries which are high risk in relation to slavery or human trafficking.

Responsibility

The governance responsibility for HBSUK's anti-slavery initiatives is as follows:

  • Overall: HBSUK Executive Team

  • Policies: People Team

  • Risk assessment, Due diligence, and Training: Governance Team

 

Relevant Policies

HBSUK operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy: HBSUK encourages all its staff, clients, and other business partners to report any concerns related to the direct activities, or the supply chains of, HBSUK. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. HBSUK's whistleblowing procedure is designed to make it easy for staff to make disclosures, without fear of retaliation. Employees, clients, or others who have concerns can complete our confidential disclosure form.

  • Employee code of conduct: The HBSUK way and EPIC values makes clear to employees the actions and behaviour expected of them when representing HBSUK. HBSUK strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

  • Environmental Management System: It is part of HBSUK’s on-going commitment to reduce the impact the company has on the environment by checking and monitoring suppliers and contractors standards through a third party questionnaire. This process of checking supplier standards can be expanded to include Human Trafficking and slavery checks to increase knowledge and confidence when dealing with suppliers and contractors.

  • Quality Management System: The Quality Policy sets out HBSUK’s commitment to high quality practices, including a collaborative partnership approach to working with our key suppliers. Our commitment to this approach allows us to have confidence in our suppliers’ commitment to preventing slavery and human trafficking in their operations, and those of their suppliers.

  • Sustainability and Environmental Management Policy: This policy builds upon our ISO14001 Environmental Management System to incorporate wider aspects of sustainability, beyond environmental aspects, and details HBSUK’s approach to sustainability. HBSUK recognises that sustainable practices are good for business, good for our commissioners and purchasers, and good for the localities and communities within which we operate. Sustainability must be an integral part of our operations, ensuring that we consider the wider impact of our business operations and decisions. This contributes to a sustainable future recognising that we need to meet the needs of the present without compromising the future.

Due Diligence

HBSUK has committed to undertaking due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. HBSUK's due diligence and reviews will include:

  • Broadly considering suppliers to assess particular product or geographical risks of modern slavery and human trafficking;

  • When engaging a new frequent supplier as part of contract negotiations/tender processes, enquire if they are a business that is required to have a Modern Slavery Human Trafficking Statement, and what policies they have in place;

  • Evaluating the modern slavery and human trafficking risks of each new supplier;

  • Where we identify high risk areas, explore those suppliers in greater detail;

  • Taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans;

  • Where a potential frequent supplier is unwilling to provide statements, or complete a questionnaire on the matter, we will consider if we commence that business relationship;

  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan, including the termination of the business relationship.

  • Ensuring contractual controls are in place with suppliers in relation to complying with Modern Slavery legislation.

 

Performance Indicators

In order to assess the effectiveness of our approach to modern slavery HBSUK will be reviewing on an annual basis the following areas:

  • Staff awareness

  • Reviewing existing supply chains; and

  • Developing a new suppliers’ evaluation process

Awareness-raising Programme

HBSUK will raise awareness of modern slavery issues via our intranet, explaining:

  • The basic principles of the Modern Slavery Act 2015;

  • How employers can identify and prevent slavery and human trafficking;

  • What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Company; and

  • What external help is available