Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Clinica London has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or in any part of its supply chain. Clinica London leads by example, by making appropriate checks on all employees, recruitment agencies and suppliers to ensure it knows who it’s working with. Clinica London is also committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains, consistent with disclosure obligations under the Modern Slavery Act 2015. Clinica London expect the same high standards from all of its contractors, suppliers and other business partners, and as part of its contracting processes, Clinica London includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and Clinica London expect that its suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for Clinica London or on its behalf in any capacity (‘Clinica Personnel’), including employees at all levels, directors, officers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment.
Responsibility for the Policy
Human Resources of Clinica London has overall responsibility for ensuring this policy complies with legal and ethical obligations, and that all those under its control comply with it.
Human Resources has primary and day-to-day responsibility for implementing this policy and monitoring its use and effectiveness.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.
Compliance with Policy
The prevention, detection and reporting of modern slavery in any part of the business or supply chain is the responsibility of all those working for Clinica London or under its control. All Clinica Personnel are required to avoid any activity that might lead to, or suggest, a breach of this policy. Modern Slavery Policy – March 2023
Clinica Personnel must notify their manager or Human Resources as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.
Clinica Personnel are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the business or supply chain of any supplier tier at the earliest possible stage. The following key signs could indicate that someone may be a slavery or trafficking victim:
the person is not in possession of their own passport, identification or travel documents;
the person is acting as though they are being instructed or coached by someone else;
they allow others to speak for them when spoken to directly;
they are dropped off at and collected from work;
the person is withdrawn or they appear frightened;
the person does not seem to be able to contact friends or family freely;
the person has limited social interaction or contact with people outside their immediate environment.
This list is not exhaustive.
If any Clinica Personnel believe or suspect that a breach of this policy has occurred or that it may occur a report must be made to the appropriate line manager or report must be made as soon as possible in accordance with the Clinica London Whistleblowing Policy.
If any Clinica Personnel are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the Clinica London supply chain constitutes any of the various forms of modern slavery, it must be raised with the appropriate line manager or Human Resources.
Clinica London 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. Clinica London is committed to ensuring no one suffers any detrimental treatment as a result of reporting, in good faith, their suspicion that modern slavery of whatever form is or may be taking place in any part of the business or in any of Clinica London supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any member of staff believes that they have suffered any such treatment, they should inform Human Resources immediately. If the matter is not remedied, and the member of staff should raise it formally using our Grievance Procedure.
Communication and Awareness of this Policy
Appropriate training on this policy, and on the risk to Clinica London’s business faces from modern slavery in its supply chains will be provided as necessary to staff.
Clinica London’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of any business relationship with them and reinforced as appropriate thereafter.
Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
Clinica London may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.
Monitoring and Review Arrangements
We will monitor the effectiveness and implementation of this policy.
This policy will be reviewed every three years unless legislation or sector developments require otherwise, ensuring that it continues to meet its objectives and take account of good practice developments.
We will consult with our employees on any review of this policy to take into account their views.
Amendments to this policy must be approved by the Medical Director and Human Resources.
Equality & Diversity
Clinica London are committed to providing services that are relevant to the needs of customers. We will treat others fairly and without discrimination.
We will ensure that all our premises, services and documentation relating to this policy are accessible and available for all customers regardless of their ‘protected characteristic’. These are defined in the Equality Act 2010 as: age, gender, race, religion, disability, sexual orientation, gender reassignment, pregnancy and maternity and civil partnerships.
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