2020 Modern Slavery and Human Trafficking Statement

Introduction

gtd healthcare continues to recognise its responsibility to address and mitigate the risk of modern slavery and human trafficking in its operations. This statement sets out our commitment and actions taken to do our part to eradicate these abhorrent practices, as well as meet the requirements of the UK Modern Slavery Act 2015 and the California Transparency Act.

Structure, business and supply chains

We want all staff that we employ to be aware of their rights and responsibilities. Recognising the important need to respond to the modern slavery crisis, we have also requested assurances from our suppliers to ensure that they too are aware of their responsibilities. Our patients are a key priority and we are working towards ensuring all staff receive training around identifying and dealing with those who may have been involved in modern slavery and human trafficking.

Policies

We are striving to ensure that slavery and human trafficking is not taking place within any of our supply chain business partners and will not tolerate such activities. We believe that it is the responsibility of every employee to help ensure all of our activities meet our high standards for behaviour and business ethics, and establishes accountability for compliance with law and policy.

The organisation promotes the need for open dialogue about potential violations and concerns, and provides confidential reporting methods through our Director of Governance and Caldicott Guardian. Where required, we have access to translation services through the Big Word.

We oppose the exploitation of workers through any form of forced or bonded labour, slavery, human trafficking or other labour practices that involve harsh or inhumane treatment. Therefore, we require our suppliers to comply with these principles and to share them with any subcontractors they may use.

With regard to our own practices/services, we set standards for a diverse workplace that provides a safe and healthy environment and complies with or exceeds local law. gtd healthcare requires an effective programme to be in place to help ensure compliance with labour laws involving migrant and foreign national workers.

Due diligence processes

We will review all business partners. These reviews include a check for either a compliance statement and a check whether adverse media, where modern slavery issues can and have been found. Terminating a contract relationship may not always be the most appropriate response based on circumstances, so substantive findings of adverse media about a business partner are handled on a case-by-case basis, according to the circumstances. A working group would be set-up to assess the company’s risk of exposure to these practices and additional activities to help mitigate any risks.

Effectiveness and performance indicators/monitoring

We recognise that the risks from modern-day slavery change, and as such our approach to preventing modern-day slavery will be reviewed annually by our Executive Management Team. This approach will monitor and review:

  • effectiveness of risk assessment processes;
  • staff training programs;
  • assessment programmes (where applicable);
  • reporting and escalation processes.

This statement is made pursuant to the relevant legal requirements of the United Kingdom.