Our Modern Day Slavery policy
Our Modern Slavery statement outlines the approach we’ve taken, and continue to take, to make sure that modern slavery or human trafficking is not taking place within our business or supply chain.
We have a zero tolerance approach to any form of modern slavery (slavery, servitude, human trafficking and forced labour).
Modern Day Slavery Statement
This statement is made pursuant to s54 of the Modern Slavery Act 2015 and sets out the steps that Hextransforma Healthcare Ltd has taken, and is continuing to take, steps to ensure that modern slavery or human trafficking is not taking place within our business or supply chain during the year ending 31 December 2018.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Hextransforma Healthcare has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
ABOUT THE ORGANISATION
Hextransforma Healthcare facilitates the delivery of global medical tourism services and healthcare to self-pay patients.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
Hextransforma Healthcare is aware of our responsibilities towards patients, service users, employees and the local community and expect all suppliers to the company to adhere to the same ethical principles. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Our internal policies replicate our commitment to acting ethically and with integrity in all our business relationships.
Currently all awarded suppliers sign up to our terms and conditions of contract which contain a provision around Good Industry Practice to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains; and that they conduct their businesses in a manner that is consistent with Hextransforma Healthcare’s anti-slavery policy.
In addition, an increasing number of suppliers are implementing the Labour Standards Assurance System (LSAS) as a condition of contract for tenders within high risk sectors and product categories.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all directly employed staff, and agencies on approved frameworks are audited to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will
- Equal Opportunities. We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities
- Safeguarding policies. We adhere to the principles inherent within both our safeguarding children and adults policies.
- Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals
- Standards of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
Our approach to procurement and our supply chain includes:
- Ensuring that our suppliers are carefully selected through our robust supplier selection criteria/processes
- Requiring that the main contractor provides details of its sub-contractor(s) to enable the company to check their credentials
- Randomly request that the main contractor provide details of its supply chain
- Ensuring invitation to tender documents contain a clause on human rights issues
- Ensuring invitation to tender documents also contains clauses giving the company the right to terminate a contract for failure to comply with labour laws
Company staff must contact and work with the Procurement department when looking to work with new suppliers so appropriate checks can be undertaken.
Supplier adherence to our values. We are zero tolerant to slavery and human trafficking and thereby expect all our direct and indirect suppliers/contractors to follow suit.
Where it is verified that a subcontractor has breached the child labour laws or human trafficking, then this subcontractor will be excluded from all future contracts and procurement activities.
The company will require that the main contractor substitute a new subcontractor.
Advice and training about modern slavery and human trafficking is available to staff through our mandatory safeguarding policies and procedures. It is also discussed at our compulsory staff induction training.
We are looking at ways to continuously increase awareness within our organisation, and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business.
OUR PERFORMANCE INDICATORS
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
APPROVAL FOR THIS STATEMENT
This statement was presented for approval at the Executive Board on 10 July 2018
Name: Jean-Luc Bressard
Position: Chief Executive Officer
Signature: Jean-Luc Bressard
Date: 10 July 2018