Northern Ireland's Leading Health and Social Care Organisation
Anti-Slavery and Human Trafficking Policy
- Purpose of Policy
The purpose of this policy is to outline the principles that supports md healthcare Ltd, Domestic Care Ltd, Optimum Nurse and Optimum Care’s (hereafter, referred to as ‘The Company’) commitment to a zero-tolerance approach to modern slavery and human trafficking.
Modern slavery covers slavery, servitude, forced and compulsory labour and human trafficking. It is often intertwined with organised crime and victims are treated as commodities and exploited for criminal gain.
The Modern Slavery Act, (the “Act”), was published in 2015 and builds upon existing legislation, consolidating a number of different offences into a single act. These offences are set out and defined below:
- Slavery – where a person exercises ownership over another
- Servitude – where a person is coerced into providing services and is unable to effect a change in his/her circumstances
- Forced Labour – where a person is forced to work or provide a service, fearing reprisal if he/she does not comply
- Human Trafficking – where a person arranges or facilitates the travel of another person with the knowledge or intention to exploit that person.
- Scope of Policy
This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, agency workers, volunteers, agents, contractors, consultants and business partners.
- Policy Statement
The Company has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.
The Company also expects the same high standards from all of its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.
Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, the Company accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.
- Responsibility for the Policy
The Board of Directors has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations.
It is the responsibility of the Senior Management Team for implementing this policy, monitoring its use and effectiveness of the policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in The Company’s business or supply chains.
Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.
- Compliance
The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company or under The Company’s control. You are required to avoid any activity that might lead to a breach of this policy.
If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or report it in accordance with the Company’s Whistleblowing Policy.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.
Our approach to procurement and our supply chain includes:
- ensuring that our suppliers are carefully selected through 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 requesting that the main contractor provide details of its supply chain;
- ensuring that our contract documents contain a clause on human rights issues;
- ensuring that our contract documents contain clauses permitting us to access a supplier’s premises, personnel, systems, books and records as required to verify the supplier’s compliance with modern slavery clauses;
- ensuring that our contract documents contain clauses giving The Company the right to terminate a contract for failure to comply with labour laws;
- supplier adherence to our values – we have a zero tolerance approach to modern slavery and expect all of our direct/indirect suppliers to have the same standpoint.
The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.
- Training and Communication
Advice and training about modern slavery is available to team members through our mandatory safeguarding children and adults training courses.
- Protecting Our Staff
The Company is committed to treating all its staff in a fair and consistent manner and in accordance with our values: Teamwork & Partnership, Openness & Honesty, Kindness, Understanding & Respect and Quality & Best Practice.
Our expectations are made clear through a number of existing policies including, but not limited to:
- Recruitment Policy, to ensure that our recruitment practices are robust and that checks are undertaken prior to employment commencing;
- Anti-Bribery and Corruption Policy, to ensure that the Group and its workforce cannot be bribed or otherwise coerced into unfair and unethical practices;
- Safeguarding Adults Policy, to ensure that there are consistent mechanisms in place or people to report concerns about vulnerable adults;
- Safeguarding Children Policy, to ensure that there are consistent mechanisms in place for people to report concerns about children;
- Whistleblowing Policy, to provide a mechanism for team members to raise concerns about alleged wrongdoing without fear of reprisal;
- Grievance Policy, to give team members a mechanism for raising concerns about their treatment at work; and
- E-learning Platform Optimum Inspire, which provides information to all team members on their statutory rights, including, but not limited to, sick pay, holiday pay etc.
- Breach of Policy
Any employee of the Company who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.
The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery
- Review of Policy
This policy will be reviewed as required and in accordance with changes in legislation.
- Linked Documents