Modern Slavery & Human Trafficking Policy

Emergency Contact

In the event of urgent advice required please call the office on 020 3868 6249 and ask for the Registered Manager or the Governance Lead:

• For clinical advice please ask for the Head of Clinical Governance
• In an emergency, please follow the hospital procedures and call the emergency team internally.

Training

• Safeguarding Adults
• Whistleblowing

1. Purpose

The purpose of this policy is to ensure that all staff at MediServices Healthcare Ltd are aware of and adhere to the Modern Slavery and Human Trafficking Policy and Procedure in line with local and national guidelines. This policy specifically relates to adults who may be at risk.

This policy must be read alongside the Safeguarding Policy. MediServices Healthcare Ltd is committed to ensuring that staff understand and follow Redditch Borough Council’s safeguarding reporting procedures. These procedures will be clearly communicated to all staff.

This policy supports MediServices Healthcare Ltd in meeting the following legal and regulatory requirements:

• The Modern Slavery Act 2015
• Health and Safety at Work Act 1974
• Human Rights Act 1998
• The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2012

2. Scope

Staff Roles Affected:

• All employees
• Registered Manager
• Other members of the management team

Service Users Affected:

• Patients

External Partners Affected:

• Suppliers and subcontractors
• Third-party staffing agencies
• Contractors providing goods or services to MediServices Healthcare Ltd

3. Objectives

• To raise awareness of modern slavery and human trafficking and reinforce MediServices Healthcare Ltd’s commitment to addressing these issues in all forms.
• To ensure that identification, protection, care, and support for victims of modern slavery and human trafficking are integral to our safeguarding procedures.
• To ensure that all suppliers and contractors meet our ethical standards and do not engage in practices related to modern slavery or human trafficking.

4. Policy Statement

Modern slavery is a criminal offence and a violation of fundamental human rights. It includes slavery, servitude, forced or compulsory labour, and human trafficking, all of which involve the exploitation of individuals.

MediServices Healthcare Ltd has a zero-tolerance approach to modern slavery and is committed to acting with integrity and transparency in all business dealings. We will implement effective systems and controls to prevent any form of modern slavery within our organisation and supply chains.

All staff will be educated about modern slavery and encouraged to report any concerns. MediServices Healthcare Ltd will support any staff member who may be at risk or a victim of modern slavery or human trafficking.

We expect all suppliers, contractors, and business partners to operate in accordance with this policy. We will not knowingly work with any organisation that engages in modern slavery or human trafficking practices.

Where cases of modern slavery or human trafficking are identified, MediServices Healthcare Ltd will work with Redditch Borough Council Safeguarding Team to protect the individual(s) involved and help eliminate such practices.

Line managers are responsible for ensuring that their teams comply with this policy in the course of their work.

Any staff member who suspects a colleague, patient, supplier, or contractor to be involved in or a victim of modern slavery must report the concern to their line manager without delay.

All staff will be informed of the Freedom to Speak Up and Whistleblowing Policy. This ensures any employee can report wrongdoing without fear of retaliation.

5. Procedure

Reporting Modern Slavery and Human Trafficking Concerns

1. A concern is identified – this could involve a patient, staff member, supplier, or third party.
2. If there is immediate danger or risk of harm, call 999 and notify the police.
3. Report the concern immediately to your line manager and the Registered Manager.
4. The Registered Manager will escalate the issue to the Redditch Borough Council Safeguarding Adults Team.
5. A notification will be made to the Care Quality Commission (CQC) via the provider portal.

6. Safer Recruitment Practice

MediServices Healthcare Ltd enforces robust recruitment procedures, including:

• Enhanced DBS checks
• Identity and right-to-work verification
• Full employment history and reference checks
• Assessment of suitability for the role

7. Use of Agency or Third-Party Staff

MediServices Healthcare Ltd only uses staff from third-party organisations that:

• Are registered with the relevant regulator, or
• Can confirm that staff are lawfully permitted to work in the UK and meet all applicable requirements for the roles provided.

8. Supplier and Contractor Compliance

• All suppliers and contractors must confirm compliance with the Modern Slavery Act 2015 or equivalent legislation.
• Suppliers will be assessed for risk of modern slavery as part of procurement and ongoing contract management processes.
• MediServices Healthcare Ltd reserves the right to audit suppliers where concerns arise.
• Any supplier found to be non-compliant may have their contract terminated.