The Modern Slavery Act 2015 requires commercial organisations of a certain size operating in the UK and supplying goods and services from or to the UK to publish a slavery and human trafficking statement each financial year, setting out the steps they have taken to ensure that slavery and human trafficking are not present in their business or supply chains.
The Act calls it a “Slavery and Human Trafficking Statement”. However, the Guidance uses the phrase “Modern Slavery Act Transparency Statement”.
An organisation is required to produce a statement if it is a body corporate or a partnership, which “carries on business” or any part of its business in the UK, which supplies goods or services and has an annual turnover of £36m or more.
The DHU Board formally adopted its first Statement at its meeting on 19 July 2017, and reviews annually. The full Statement is presented here:
Statement for financial year 2023/24
This statement is made according to s.54 of the Modern Slavery Act 2015.
It sets out the steps that DHU Health Care C.I.C. (‘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. The statement is displayed on DHU’s website:
Introduction
DHU Healthcare is a not-for-profit Community Interest Company. We are led by a Board made up of Executive Directors and Non-Executive Directors - who together share a wealth of experience and knowledge through many years of working within the NHS, NHS provider services, Local Authorities and other public and private sectors.
Our supply chains include procurement of agency staff, medical consumables, facilities maintenance, utilities, and waste management. No modern slavery or human trafficking should take place in any part of our business or supply chain. Section 54 of the Modern Slavery Act 2015 requires us to set out the steps we have taken during the financial year to ensure this is the case. As a community interest company, DHU Healthcare is committed to this principle. This statement sets out what we have done to understand all potential modern slavery and human trafficking risks and how we mitigate against them using effective systems, policies, and controls.
With a workforce of around 3,000, DHU Healthcare offers a range of service provisions in the Midlands to around 11 million people. We collaborate with partners and colleagues across NHS systems, GP federations, and other private provider companies, offering innovative, integrated healthcare solutions that ensure all our patients and communities can access the right care in the right place at the right time.
As part of the NHS frontline, we lead urgent care within emergency departments, urgent treatment centres, GP and primary care surgeries, and out in our communities. We offer a full range of clinical specialist services, both ‘in and out of hours’, provided by a diverse workforce made up of medical, nursing, allied health, and support teams.
Our business offer, with contracts currently in the region of £160 million, includes community nursing, urgent treatment, primary care streaming, urgent on-day primary care, GP home visiting, phlebotomy, community hospital medical cover, telephone consultation support, weekend palliative care home visiting and NHS111.
Find out more about DHU Healthcare here.
All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking.
Our ‘Modern Slavery: Human Trafficking’ factsheet provides information to all DHU staff - highlighting modern slavery, human trafficking and forced labour, applicable legislation and the critical signs for staff to look out for when any stakeholders, including patients, colleagues, partners, suppliers or contractors may potentially be a victim of modern slavery. Staff are expected to report concerns about slavery and human trafficking, and management is expected to act upon them following our policies and procedures.
We have zero tolerance for slavery and human trafficking. We are guided by strict ethical values in all our business dealings and expect our suppliers (the companies we do business with) to adhere to these same principles. DHU Healthcare’s internal policies and procedures support the mitigation of risks relating to the potential for modern slavery or human trafficking.
The principal risks related to slavery and human trafficking are reputational, lack of assurance from suppliers and contractors and ensuring staff are trained to understand modern-day slavery and human trafficking (and what to do when it’s suspected).
We protect DHU Healthcare against the risks of modern slavery and human trafficking in our own business and our supply chain through these mitigations:
- Recruitment & Selection Procedure: Includes conducting checks for eligibility to work in the UK for all employees to safeguard against human trafficking (anti-slavery) or individuals being forced to work against their will.
- Freedom to Speak Up Procedure: This procedure ensures that all employees know they can raise concerns about how colleagues are being treated or concerns around practices within our business or supply chain without fear of reprisals.
- Agency checks: Agency checks on approved frameworks are audited to provide assurance that pre‐employment clearance has been obtained for agency staff.
- Equality and Diversity: outlines our 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.
- Terms and Conditions: We adopt controls that protect staff from poor treatment and exploitation to comply with all respective laws and regulations. These include the provision of fair pay rates, fair Terms of Conditions of Employment and access to training and development opportunities.
- Procurement policy: Most of our products are purchased from UK- or EU-based firms, who may also be required to comply with the requirements of the UK Modern Slavery Act (2015) or similar legislation in other EU states. We require all suppliers to comply with the provisions of the UK Modern Slavery Act (2015) through our purchase orders and tender specifications. As part of all formal tender processes, DHU Healthcare will request a compliance statement regarding Modern Slavery and Human Trafficking. Where possible and consistent with the Public Contracts Regulations, we build long‐standing relationships with suppliers with a shared commitment to best value and integrity – including a commitment to reducing the risk of modern slavery and human trafficking within their businesses.
- Anti-Fraud, Bribery & Corruption Procedure: This procedure ensures that business is conducted in an open, honest, and ethical manner. It 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.
We will make an annual compliance statement against these mitigations within our Annual Report and Accounts.
Staff can access advice and training through our Safeguarding Children and Adults training, our Safeguarding policies and procedures, and our Safeguarding leads. We expect all DHU Healthcare colleagues to complete our essential learning module on Modern Slavery.
DHU monitors reports received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified. To date, none have been received.
The Board of Directors considered and approved this statement on 02/10/2024 and will continue to support the legislation's requirements.