Modern Slavery Statement
Issue Date: 10/05/2023
This statement applies to CHEC (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 1st July 2023 to 30th June 2024.
B) Organisational structure
CHEC Head Office is located in Preston, Lancashire, with Ophthalmic and Endoscopic Hospitals situated across the UK. The organisation is controlled by a Board of Directors.
The labour supplied to CHEC in pursuance of our operation is carried out in the United Kingdom in the following regions: North, Midlands, South and Wales.
CHEC considers that modern slavery encompasses:
- Human trafficking
- Forced work, through mental or physical threat
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse
- Being dehumanised, treated as a commodity or being bought or sold as property
- Being physically constrained or to have restriction placed on freedom of
CHEC is committed and acknowledges our responsibilities in relation to tackling modern slavery and ensure we continuously comply with the provisions within the Modern Slavery Act 2015. We understand that this requires an ongoing review of both our internal practices in relation to our labour force and, additionally, our supply chains.
CHEC does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to CHEC in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. CHEC strictly adheres to the standards required in relation to its responsibilities under relevant employment legislation in the UK.
E) Supply Chains
CHEC’s main supply chains relate to Ophthalmology and Endoscopy as well as wider business functions. The supply of equipment, products, instruments, consumables, and medical uniforms are from various suppliers in the United Kingdom, Europe, and international supply chains. Some of our suppliers are intermediary traders and therefore have further contractual relationships with lower tier suppliers, where our first tier suppliers are intermediary traders, we ask that they can ensure their suppliers are complaint with this policy and have carried out their due diligence to evidence this.
In order to ensure that those within our supply chain comply with our commitment, we ensure the below:
- All suppliers are compliant with the Modern Slavery Act 2015 and any other local regulations
- Each supplier has their own anti-slavery/human trafficking policy
- Each supplier works to monitor, identify, and address any potential risks within their own supply chain
- Each supplier operates a zero-tolerance approach to slavery and human trafficking
- Each supplier does not conduct business knowingly with anyone engaged in slavery and human trafficking or knowingly permit them to be carried out in any part of its business
In order to monitor the above, CHEC completes due diligence to ensure compliance on an ongoing basis with both new and existing suppliers. CHEC also ensures robust contractual arrangements are implemented and applies monitoring procedures as and when appropriate. CHEC takes a zero-tolerance approach to non-compliance and any instances of such will be managed on a case-by-case basis.
CHEC’s procurement approach for both goods and services remain robust. For clinical procurement, we apply the NHS Standard Contract or Sub-Contract as appropriate, requiring suppliers to comply with relevant legislation.
CHEC wish to ensure all employees have both understanding and awareness of modern slavery and human trafficking and so CHEC staff receive appropriate training. To date, all commercial and procurement employees at CHEC have received training on ethical and staffing issues in procurement. Ethical and staffing issues form a key part of our induction for new entrants to the Commercial team.
F) Potential Exposure
We consider our exposure to slavery/human trafficking to be relatively limited. Nonetheless, CHEC has taken steps to ensure that such practices do not take place in our business nor the business of any organisation that supplies goods and/or services to us.
CHEC carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in our organisation or supply chains, including conducting a review of the controls of our suppliers.
CHEC has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, CHEC intends to take the following steps to ensure that modern slavery is not taking place:
- reviewing our supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;
- undertaking impact assessments of its services upon potential instances of slavery;
- any actions taken to embed a zero-tolerance policy towards modern slavery;
H) Key Performance Indicators
CHEC has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the organisation or its supply chains.
- 100% of our suppliers to have agreed to the supplier Code of Conduct
Modern Slavery Training
- Ensure that 100% of all existing and new employees, and contractors complete the compulsory Modern Slavery training
- Ensure that 100% of employees who have roles dealing with suppliers, such as the Procurement Team receive ongoing updates and notifications regarding business & human rights, and specifically Modern Slavery
CHEC has a policy which further defines its stance on modern slavery – HR-POL- 09 Anti-Slavery Policy V1.
CHEC provides the following training to staff to effectively implement its stance on modern slavery via blended learning training via e learning and training on modern slavery polices.
K) Slavery Compliance Officer
CHEC has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisations obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.