This statement sets out Healthcare Locums (HCL) Ltd’s commitment to continually improving its practices to combat slavery and human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st January 2016 to 31st December 2016.
As a provider of health and social care workforce solutions, we and our supply chain recognise that we have a responsibility to take a robust approach to slavery and human trafficking.
HCL Group structure and supply chains
We are a provider of recruitment services in the health and social care sector. We are the parent company of the Healthcare Locums Ltd Group (Group). The Group has over 500 employees worldwide and operates in the UK and Australia. Under The Modern Slavery Act 2015 the Group is required to provide this statement. The Group operates with the following business units:
- Healthcare Locums Ltd (Parent company)
- HCL Healthcare Ltd
- HCL Doctors Ltd
- HCL Nursing Ltd
- HCL Social Care Ltd
- HCL Permanent Ltd
- HCL Managed Services Ltd
- JCJ Locums Ltd
- HCA International
Our supply chains include:
- Temporary workers for the health and social care sector
- Subcontracting suppliers of temporary workers for the health and social care sector
- Learning and development/training
- Laboratory Services
- Occupational Health Services
- Employment Background Checking Services
- Print Solution
- Cleaning & Janitorial
- Office furniture
- Confidential waste supplier
- Couriers & Postal Services
All of which are based in the UK.
Our supply chain outside of the UK includes:
- Supply of (temporary) workers
- Outsource providers
Some of which are based in North America, India and Europe.
The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
- The Group confirms that prior to any supplier being included on our supply chain they have policies and procedures that are congruent with our intention to combat slavery and human trafficking.
- If suppliers do not have their own Modern Slavery policy, we will make our policy available and obtain assurances of the supplier’s commitment to follow prior to supply commencing.
- If, after supply commences, we believe there is an actual breach or risk of breach , we will investigate this following our Complaints & Serious Untoward Incident Policy.
Responsibility for the HCL Group’s anti-slavery initiatives is as follows:
Policies – In addition to the Modern Slavery policy, there are several other Group policies that are used to support the intention of combating slavery and human trafficking and identifying risk. These policies are:
- Recruitment & Selection policy: All internal and temporary workers are screened and vetted in line with best practice and relevant legislation to ensure: Authentic and legal documentation, right to work in the UK and identity, as well as assessing for any concerning behaviours/fears/pay or banking irregularities or health issues that may require further review in line with combating Modern Slavery.
- Whistleblowing policy: We encourage all of our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the HCL Group. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The HCL Group’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns may raise them with the individuals identified within the policy or they can contact Public Concern at Work’s confidential helpline.
- Employee Handbook – Code of Conduct: The HCL Group’s code makes clear to employees the actions and behaviour expected of them when representing the HCL Group. The HCL Group strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
- Procurement & Authorisation Levels policy and procedure: The HCL Group is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. This includes the supplier confirming their business process conform to the Modern Slavery Act (2015). The HCL Group works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. If there are breaches found in the supplier’s adherence to the Modern Slavery Act, or Code of Conduct expected, this will require improvement reviews and may result in the termination of the business relationship if the breaches cannot be resolved. We seek to confirm adherence to combating slavery and human trafficking in our supply chain by requesting this assurance on our supplier questionnaire prior to commencing supply.
- Safeguarding of Children policy: Sets out the expectation of temporary workers in identifying, recording and reporting actual or potential safeguarding risk to children. This includes the identification of actual or potential risk of slavery and human trafficking. Internal staff use this policy when there is an allegation raised about safeguarding a child about a temporary worker, or a temporary worker makes contact to raise a concern occurring within their work placement.
- Safeguarding of Vulnerable Adults policy: Sets out the expectation of temporary workers in identifying, recording and reporting actual or potential safeguarding risk to vulnerable adults. This includes the identification of actual or potential risk of slavery and human trafficking. Internal staff use this policy when there is an allegation raised about safeguarding an adult, raised about a temporary worker, or a temporary worker makes contact to raise a concern occurring within their work placement.
- Diversity & Inclusion policy: Sets out the expectations we have of all our employees, temporary workers and suppliers to embrace diversity and inclusion. In cases where we believe this is not the case we will be mindful of considering whether actual or potential slavery and human trafficking may be a contributing factor. Should there be any cause for concern the policy identifies possible courses of action.
- Health & Safety (including Lone Worker) policy: In accordance with its duty under Section 2(3) of the Health and Safety at Work Act 1974 and in fulfilling its obligations to both staff and other persons who may be affected by its activities, HCL group aims to achieve a working environment which is free of work related accidents and ill-health and to this end we will pursue continuing improvements from year to year. This includes any actual or potential risk to health & safety identified with slavery and human trafficking assessments and investigations.
- Data Protection policy: The Group is registered with the Information Commissioner’s Office (ICO). This policy ensures the Group adheres to its data protection obligations under the DPA and appropriate action to take where a breach or suspected breach has taken place. The aim of the policy, in line with its DPA obligations, is to ensure all information including sensitive information is processed lawfully, subject’s data is held with their knowledge, consent and for a particular purpose. Subjects are also entitled to request their information by making a subject access request.
- Corporate Social Responsibility Policy: Sets out to ensure we behave in a thoughtful and meaningful way in all of our work related transactions. Being mindful of the actual or potential risk of slavery and human trafficking is factored in to all of our transactions.
- Quality Assurance Policy: Provides the overview of the Group’s commitment to continued improvement, as well as monitoring and measuring adherence to policy and procedures through scheduled audit, policy updates and reviews. Where risk or actual breaches are found, the policy outlines the various actions that can be used to correct, reduce or mitigate future risk.
- Risk assessments: An initial risk assessment is completed with a new supplier via a supplier questionnaire; confirming adherence to policy intent and new employees/temporary worker recruitment and vetting process. Scheduled audits are completed to identify risks. At any time where a breach or potential breach is identified, either internally or in the supply chain, it is reviewed using the Complaints & Serious Untoward Incident policy.
- Investigations/due diligence: At any time where a breach or potential breach is identified, either internally or in the supply chain, it is reviewed using the HCL Complaints & Serious Untoward Incident policy, in conjunction with the National Referral Mechanism framework: https://www.gov.uk/government/publications/human-trafficking-victims-referral-and-assessment-forms/guidance-on-the-national-referral-mechanism-for-potential-adult-victims-of-modern-slavery-england-and-wales
A referral to the Home Office is made using the National Referral Mechanism when referral thresholds are met. This allows for national action to combat modern slavery and provides potential victims with the appropriate support.
HCL Group undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. HCL Group’s due diligence and reviews include assessing the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking in areas which may include but not limited to;
- evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment];
- reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
- conducting supplier audits or assessments with a focus on slavery and human trafficking
- where general risks are identified;
- taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans to include specific amendments to be made and adhered to. This will be confirmed through a re-auditing process;
- participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking
- using, where available, ethical supplier databases, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
- invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the suspension or termination of the business relationship and reporting to the authorities as appropriate.
- The HCL Group requires new internal personnel to complete an online modern slavery training course within three months of their commencement date. For existing personnel training, an annual refresher must be completed.
- Modern Slavery Assessment Questionnaire for supply chain and subcontractor verification expected to be in place by 1 April 2017, whereby the HCL Group evaluates potential suppliers before they enter the supply chain; and
- reviewing its existing supply chains and subcontractors against the Modern Slavery Assessment Questionnaire expected to be completed by 30 June 2017, whereby the HCL Group evaluates all existing suppliers.
The HCL Group’s modern slavery training will be the main mechanism for raising awareness about the Modern Slavery Act, which will include:
- our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- how to identify the signs of slavery and human trafficking;
- what initial steps should be taken if slavery or human trafficking is suspected;
- how to escalate potential slavery or human trafficking issues to the relevant parties within the HCL Group;
- what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger together” initiative;
- what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
- what steps HCL Group should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the HCL Group’s supply chains.
HCL Group has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the HCL Group’s temporary worker supply is provided with Safeguarding Children and Vulnerable Adult training to equip them to identify all types of abuse. Guidance on Safeguarding Children and Vulnerable Adults, including slavery and human trafficking, and professional responsibility to report accordingly is also provided in the temporary worker’ handbooks. This training is updated annually.
This statement has been approved by the HCL Group’s board of directors, who will review and update it annually.
Chief Executive Officer