Modern Day Slavery Act
Modern Slavery Statement 2018/19
Bromley Healthcare aims to follow good practice and take all reasonable steps to prevent slavery and human trafficking. Our commitment to preventing slavery and human trafficking centres around our commitment to take steps that:
Prevent slavery and human trafficking in our corporate activities and supply chains; and
Ensure that all of our employees are aware of the Modern Slavery Act 2015 and their safeguarding duty to protect and prevent harm and abuse when it is identified or suspected that an individual may be or is at risk of modern slavery/human trafficking.
Bromley Healthcare was established on 1 April 2011 to provide out-of-hospital health services in Bromley. We’ve grown from working in just one borough to being one of the UK’s leading providers of community health services. We now employ approximately 800 staff caring for people across Bromley and the surrounding boroughs of Bexley, Croydon, Lewisham and Greenwich.
As a Community Interest Company we are not an NHS organisation; however, the majority of the healthcare services we deliver are commissioned by local Clinical Commissioning Groups under the NHS Standard Contract. We follow many national NHS policies, standards and frameworks and have signed up to a number of agreements with other NHS organisations, including the London Procurement Partnership.
Working with Suppliers
Via our contracted procurement service Essentia, we will ensure our supplier base and associated supply chain that provides goods and/or services to the organisation has taken the necessary steps to ensure modern slavery is not taking place.
The majority of our purchases utilise existing supply contracts or frameworks which have been negotiated under the NHS Standard Terms and Conditions of Contract, these all have the requirement for suppliers to have suitable anti-slavery and human trafficking policies and processes in place. Where a suitable framework exists we use them in preference to tendering. These frameworks are run by national procurement agencies and local NHS procurement hubs and contain the standard NHS Terms & Conditions.
Our largest single supplier, NHS Supply Chain, has a Supplier Code of Conduct which outlines main principles for suppliers in the area of labour standards and worker welfare. All suppliers are expected to adhere to these principles which address issues such as child labour, forced labour, wages, working hours as well as health and safety. The Supplier Code of Conduct is a contractual requirement and has been part of all NHS Supply Chain Framework Agreements since 2009. The procurement service is committed to ensuring that this is monitored and reviewed with its supplier base.
The procurement service’s senior team are all Chartered Institute of Purchasing and Supply (CIPS) qualified and uphold the CIPS’s code of professional conduct and practice relating to procurement and supply. All members of the procurement team are required to undertake safeguarding training at a level appropriate to their roles and responsibilities.
In addition, template commercial agreements will be updated by the procurement service to include an obligation that suppliers will comply with the Act and ensure that their suppliers and sub-contractors will too.
Our commitment to preventing modern slavery and trafficking begins with our recruitment process. We adhere to the National NHS Employment Checks / Standards (this includes employees UK address, right to work in the UK and suitable references). Agency workers are engaged through recruitment agencies signed up to the London Procurement Partnership, which requires them to comply with the Modern Slavery Act.
Our Safeguarding policies include information about modern slavery and human trafficking, and clearly outline the role and responsibilities of all staff. We have a named Adult Safeguarding Lead and a named Children’s Safeguarding Lead, both of whom are available to provide safeguarding advice and support to staff. Our Adult Safeguarding Lead is also a member of the Bromley Safeguarding Adults Board – Modern Slavery Task & Finish group working on borough wide Modern Slavery policies.
Safeguarding training is mandatory for all staff and includes information on trafficking and modern-day slavery in order to promote the knowledge and understanding of escalating concerns via the Home Office national referral mechanism/duty to notify process. Clinical staff are also encouraged to undertake specific Modern Slavery eLearning provided by the local authority.
Staff are encouraged to raise any concerns that they might have. We have a Whistleblowing policy which details how staff, sub-contractors and contractors can raise any concerns that they may have confidentially, if they are concerned about raising the matter via their line manager or head of service.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery Statement for the year 2018/19.