Modern Slavery Act 2015

Modern Slavery Act

What is the Modern Slavery Act 2015?

The DHU is committed to combatting slavery and human trafficking. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015.

It sets out the steps that DHU Health Care CIC (‘DHU’) has undertaken – and is continuing to take – to ensure that modern slavery or human trafficking is not taking place within its business or supply chain.

DHU has a zero tolerance approach to any form of modern slavery. The Company is committed to acting ethically, with integrity and transparency in all business dealings.

DHU is committed to creating effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.


The organisation

DHU is a social enterprise ‘not-for-profit’ community interest company providing clinical and administrative services to the National Health Services (‘NHS’) in England. The Company’s operations are solely in England.


The salient human rights issues

The Company’s services supplied to the NHS are predominantly of a clinical nature. As such DHU is a ‘people’ organisation. As a consequence it is Company policy to ensure that all employees, agency staff, contractors and suppliers are aligned to and adhere to the Company’s ethos of being a ‘caring organisation’.

Adherence to the DHU ethos also necessitates that the Company operates in an ethical and transparent manner.
To this end due recognition of the risks to the Company and the services it supplies to the NHS are at the forefront of all Company policies not lease in the area of safeguarding against human trafficking (anti-slavery) or individuals being forced to work against their will.


The policies

DHU operate a number of internal policies to ensure that it is conducting business in an ethical and transparent manner. These include the following relevant policies:

1. Recruitment & Selection Policy: Includes conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking (anti-slavery) or individuals being forced to work against their will.
2. Whistle-Blowing Policy: Ensures all employees know they can raise concerns about how
colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
3. Anti-Bribery, Gifts & Hospitality Policy: Ensures that business is conducted in an open, honest and ethical manner with a zero tolerance stance to bribery and corruption.
4. Fraud, Bribery & Corruption Policy: Details the Company’s commitment to the proper use of public funds and outlines roles and responsibilities for the prevention of fraud, bribery and corruption.
5. Equality and Diversity for Staff Policy: This policy sets out the Company’s commitment to provide an inclusive environment which promotes equality, encourages and values diversity, eliminates discrimination (including bullying, harassment and victimisation) and respects the rights and dignity of all employees and patients.
DHU expect employees, patients, visitors, suppliers and other stakeholders to treat people with dignity and respect.


The suppliers

DHU operates and maintains a preferred supplier list. The Company conduct due diligence on all suppliers before allowing them to become a preferred supplier.

This due diligence includes regular interviews with partners and stakeholders/ an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery/audits which include a review of working conditions.

Suppliers are required to comply with all of DHU’s policies and compliance forms part of the contract with suppliers. In addition, suppliers are required to confirm that no part of their business operations contradict DHU policies, where appropriate.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that, for example:

1. They have taken steps to eradicate modern slavery within their business
2. They hold their own suppliers to account over modern slavery
3. They pay employees at least the national minimum wage / national living wage, and
4. The contract will be terminated if instances of modern slavery come to light.


Performance indicators

The Company will know the effectiveness of the steps taken to ensure that slavery and/or human trafficking is not taking place within the business or supply chain if, for example:

• Reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified
• The use of labour monitoring and payroll systems
• The use of whistle-blowing and/or grievance processes
• The system for supply chain verification including the level of communication and personal contact with next link in the supply chain