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Modern Slavery Statement

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Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and is relevant to Community Health and Eyecare Limited (“CHEC”) and all its group companies. At CHEC, we are committed to ensuring that modern slavery and human trafficking do not take place within our business operations or supply chains. As a leader in the healthcare industry, we recognise our responsibility to act ethically and with integrity in all our business relationships. This statement outlines the steps we have taken, and continue to take, to prevent modern slavery and human trafficking within our business and supply chains. Information included in the statement refers to the financial year ending 30th June 2024.

Our Business

CHEC is an independent healthcare provider with our head office based in Preston, Lancashire and 28 hospitals sites and multiple other community locations throughout England. CHEC provide services to a diverse range of patients under multiple specialities including Ophthalmology, Endoscopy, ENT and Dermatology.

The organisation is controlled by a Board of Directors and currently has around 500 employees based across our geographical reach.

Our Commitment

CHEC is committed and acknowledges our responsibilities in relation to tackling modern slavery to ensure we continuously comply with the provisions within the Modern Slavery Act 2015.  We understand that this requires an ongoing review of both our internal practices in relation to our labour force and, additionally, our supply chains.

CHEC commits to never enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude, unethical practices and forced or compulsory labourNo labour provided to CHEC in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. CHEC strictly adheres to the standards required in relation to its responsibilities under relevant employment legislation in the UK and undertakes compliance checks for all new members of staff.

    Our Method

    • CHEC carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in our organisation or supply chains, including conducting a review of the controls of our suppliers.
    • CHEC carries out (and request that any third party agencies working on our behalf carry out) due diligence and compliance checks throughout all stages of the recruitment process including checking conducting right to work checks.
    • CHEC review all supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery.
    • CHEC are committed to undertake impact assessments of its services upon identification of potential instances of slavery and taking a proactive approach through supplier management to ensure earlier intervention where a risk is posed;
    • CHEC takes actions to embed a zero-tolerance policy towards modern slavery;
    • CHEC has a policy which further defines its stance on modern slavery (HR-POL- 09 Anti-Slavery Policy) which is reviewed annually in line with our commitment.

    Training and Awareness

    CHEC are keen to grow or risk aware culture, including in relation to risks posed of modern slavery and human trafficking. We are keen to ensure all colleagues understanding their roles in preventing these practices.

    CHEC provides the training to staff to effectively implement its stance on modern slavery via blended learning training and e-learning in accordance with our training Matrix.

    CHEC undertake an annual Training Needs Analysis where additional training needs, including those relating to Modern Slavery and Human Trafficking are considered.

    Key Performance Indicators

    CHEC has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the organisation or its supply chains.

    Supplier Engagement

    • 100% of our suppliers to have agreed to the supplier Code of Conduct

    Modern Slavery Training

    • Ensure that 100% of all existing and new employees, and contractors complete the compulsory Modern Slavery training.
    • Ensure that 100% of employees who have roles dealing with suppliers, such as the Procurement Team receive ongoing updates and notifications regarding business & human rights, and specifically Modern Slavery.

    Supply Chains

    CHEC’s main supply chains relate to Ophthalmology and Endoscopy as well as wider business functions. The supply of equipment, products, instruments, consumables, and medical uniforms are from various suppliers in the United Kingdom, Europe, and international supply chains. Some of our suppliers are intermediary traders and therefore have further contractual relationships with lower tier suppliers, where our first tier suppliers are intermediary traders, we ask that they can ensure their suppliers are complaint with this policy and have carried out their due diligence to evidence this.

    In order to ensure that those within our supply chain comply with our commitment, we ensure the below:

    • All suppliers are compliant with the Modern Slavery Act 2015 and any other local regulations
    • Each supplier has their own anti-slavery/human trafficking policy
    • Each supplier works to monitor, identify, and address any potential risks within their own supply chain
    • Each supplier operates a zero-tolerance approach to slavery and human trafficking
    • Each supplier does not conduct business knowingly with anyone engaged in slavery and human trafficking or knowingly permit them to be carried out in any part of its business

    In order to monitor the above, CHEC completes due diligence to ensure compliance on an ongoing basis with both new and existing suppliers. CHEC also ensures robust contractual arrangements are implemented and applies monitoring procedures as and when appropriate. CHEC takes a zero-tolerance approach to non-compliance and any instances of such will be managed on a case-by-case basis.

    CHEC’s procurement approach for both goods and services remain robust. For clinical procurement, we apply the NHS Standard Contract or Sub-Contract as appropriate, requiring suppliers to comply with relevant legislation.

    CHEC wish to ensure all employees have both understanding and awareness of modern slavery and human trafficking and so CHEC staff receive appropriate training. To date, all commercial and procurement employees at CHEC have received training on ethical and staffing issues in procurement. Ethical and staffing issues form a key part of our induction for new entrants to the Commercial team.

    Looking Ahead and Exposure

    We consider our exposure to slavery/human trafficking to be relatively limited. Nonetheless, CHEC has taken steps to ensure that such practices do not take place in our business nor the business of any organisation that supplies goods and/or services to us

    We are committed to continuously improving our efforts to prevent modern slavery and human trafficking within our business and supply chains. Over the next year, we plan to:

    • Enhance our risk assessment processes to better identify and address potential areas of concern.
    • Expand our supplier audit program to include more frequent and detailed evaluations.
    • Increase our engagement and collaboration with stakeholders to share best practices and develop more effective strategies to combat modern slavery through our enhanced Contract Management Processes.

    Slavery Compliance Officer

    CHEC has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisations obligations in this regard.

    This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.