Modern Slavery Act - HTG-UK Statement
Modern Slavery Act – Transparency in Supply Chains Statement.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. Modern Slavery is a serious high-harm crime which is also hidden and hard to detect. Consumers, investors and others are usually unaware as to whether this crime has taken place in the supply chains of a business which operates or trades within the UK.
It is intended that this declaration will aid the detection and elimination of modern slavery in supply chains of businesses. All companies with a turnover of £36m or above (defined as a large company under the Companies Act 2006) are subject to implementing the transparency in supply chain provision; providing fair competition and significant social and economic benefit.
Our statement sets out the steps that Health Transportation Group (UK) Limited has taken, and continues to take, to provide assurance that modern slavery and human trafficking is not taking place within our business or through our supply chain.
The Health Transportation Group (UK) Limited has a zero-tolerance approach to any form of modern slavery; slavery, human trafficking and forced labour/servitude. We are committed to working ethically, with integrity and transparency and to safeguard against any forms of slavery taking place within our business or through our supply chains.
The Health Transportation Group has a responsibility to stakeholders, service users, employees and our local communities to ensure that there are no incidents of modern slavery or human trafficking taking place within our supply chains or through any part of our business.
Our policies enforce our commitment to working ethically, and with integrity.
Recruitment Policy We operate a robust recruitment policy which includes conducting eligibility to work in the UK checks for all directly employed personnel. Pre-employment checks are completed on all staff to safeguard against human trafficking, and to prevent individuals being forced to work against their will.
Equal Opportunities HTG has a range of controls in place to protect individuals from poor treatment and/or exploitation. Employees are provided with a contract of employment, which complies with all respective laws and regulations.
Strategic Plan Sets out to explain the manner in which we behave as an organisation and how we expect our employees and suppliers to behave.
Safeguarding We adhere to the principles of our Safeguarding Children and Vulnerable Adults policies. Our policies comply with the local Safeguarding Boards and multiagency agreements and are approved by our Commissioning Boards.
Whistleblowing We endorse awareness and openness through our whistleblowing policy. Our staff are empowered to raise concerns about how colleagues or people receiving our services are being treated without fear of reprisal.
Our Approach to Procurement
Our suppliers are carefully selected through a robust supplier selection process and must provide details of any sub-contractor engaged by them in providing a service to HTG. Any company that does not pass the credential checks is not listed as one of our approved suppliers and will not undertake any work for HTG.
Suppliers must adhere to HTG’s zero tolerance on modern slavery and human trafficking.
All company agreements with our suppliers contain information on human rights issues. Our agreement stipulates that any breach in human rights must be reported straight away to HTG. A clause has been written allowing HTG the right to terminate any agreement where suppliers have failed to adhere to labour laws.
HTG staff will work with the finance team, both in Spain and the UK, when introducing potential new suppliers. Staff must engage companies from the approved list of suppliers.
Training in the identification of modern slavery and trafficking is included as part of our compulsory induction programme and continues through our Safeguarding training. Advice and guidance for employees is provided through our appointed Safeguarding Leads who are level 4 trained. We adopt a discreet “Open Door” policy between management and staff in an effort to ensure that appropriate feedback and reporting mechanisms are in place so that any potential breaches can be escalated through the right channels and addressed in a timely manner.
Modern slavery can take different forms, some may not be obvious to the casual observer.
It can range from commonly highlighted abuse such as forced labour, human trafficking and sexual exploitation to less well-recognised forms such as withholding of passports, debt bondage and excessive charges around housing.
Risks can be anywhere around the business functions, we understand what our supply chain looks like, and consider where vulnerabilities may exist. Regular reviews of the associated risks allows us to direct resources to mitigate risks. We review existing processes and expand them as appropriate to reflect insights gained. The rigour of the company’s due diligence process is commensurate to the levels of risk across the business.
Executive Board Responsibility
The Executive Board has commissioned this document and has oversight of the due diligence process through regular reports presented to the Board. The Board, as part of the strategic plan discussions, considers the risks associated with modern slavery.
Measuring our performance
The effectiveness of our process is measured by the number of incidents reported by our employees, our stakeholders, the public and law enforcement agencies.
To date no reports have been received on behalf of the Health Transportation Group (UK) Limited or in relation to anyone within our supply chain to identify any areas of concern relating to modern day slavery.