Last updated: September 2024
Introduction
Modern slavery as defined in the Modern Slavery Act 2015 (revised), is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for another person's gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.
At Clinical Partners, we have a zero-tolerance approach to modern slavery, and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking.
Our business and supply chains
We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.
If we become aware or have suspicion of modern slavery we will act immediately against the supplier and report it to the authorities.
Supplier due diligence
Clinical Partners conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:
- Assessing risks in the provision of particular services
- Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
- Requiring improvements to substandard employment practices
- Sanctioning suppliers that fail to improve their performance in line with our requirements
We require all suppliers to attest that:
- They don't use any form of forced, compulsory or slave labour
- Their employees work voluntarily and are entitled to leave work
- They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
- They don't require employees to post a deposit/bond and don't withhold their salaries for any reasons
- They don't require employees to surrender their passports or work permits as a condition of employment.
How employees should report suspicions of modern slavery
Should a staff member have any concerns regarding modern slavery they should contact their line manager immediately. These concerns may be around third party suppliers working with Clinical Partners or may be around phone calls they receive from the public. The Whistleblowing policy should be referred to if the member of staff believes their line manager is not the best person to deal with the situation.
Listed below are some of the signs that might indicate trafficking. This is not an exhaustive list. If you have any concerns about an individual or a situation please call the police.
Physical appearance
Show signs of physical or psychological abuse, look malnourished or unkempt, anxious/agitated or appear withdrawn and neglected. They may have untreated injuries.
Isolation
Rarely be allowed to travel on their own, seem under the control, influence of others, rarely interact or appear unfamiliar with their neighbourhood or where they work.
Relationships which don’t seem right – for example a young teenager appearing to be the boyfriend/ girlfriend of a much older adult.
Poor living conditions
Be living in dirty, cramped or overcrowded accommodation, and/or living and working at the same address
Restricted freedom of movement
Have no identification documents, have few personal possessions and always wear the same clothes day in day out. What clothes they do wear may not be suitable for their work
Have little opportunity to move freely and may have had their travel documents retained, e.g. passports
Unusual travel times
Be dropped off/collected for work on a regular basis either very early or late at night
Unusual travel arrangements - children being dropped off/picked up in private cars/taxis at unusual times and in places where it isn’t clear why they’d be there.
Reluctant to seek help
Avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of violence to them or their family.