St George’s and the Modern Slavery Act
15St George’s is committed to upholding the provisions of the Modern Slavery and Human Trafficking Act 2015.
We also take very seriously our commitment towards ensuring that no modern slavery or human trafficking takes place in any part of our organisations, or across the many services we run out of St George’s Hospital (Tooting); Queen Mary’s Hospital (Roehampton); as well as in the community.
The Trust is committed to ensuring that there is no modern slavery or human trafficking in our supply chains, or within our organisation. Our internal policies reflect our commitment to acting ethically and with integrity in all our interactions – with staff, patients and suppliers of goods and services.
Currently, all suppliers that provide us with goods and services sign up to our terms and conditions of contract, which contain a provision around Good Industry Practice to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains. The provision around Good Industry Practice also ensures that the suppliers conduct their businesses in a manner that is consistent with the Trust’s stance on anti-slavery.
In addition, an increasing number of suppliers are implementing the Labour Standards Assurance System (LSAS) as a condition of contract for tenders within high risk sectors, and product categories as referenced in the Government’s Modern Slavery Strategy. Many aspects of the LSAS align to the seven reporting areas that the Government has outlined, and should appear within any slavery and human trafficking statement.
We have put in place a range of policies and procedures to ensure that we are conducting business in an ethical and transparent manner. These include:
- Recruitment policy – Our recruitment processes ensure we conduct eligibility to work in the UK checks for all directly employed staff, and agencies on approved frameworks are audited to provide assurance that pre-employment clearance has been obtained for agency staff. This is to safeguard against human trafficking, or individuals being forced to work against their will
- Equal Opportunities – We have a range of controls to protect staff from poor treatment and/or exploitation, that comply with all respective laws and regulations. These controls ensure we have fair terms and conditions of employment and that there is fair access to training and development opportunities
- Safeguarding policies – We apply our safeguarding children and safeguarding adults’ policies. Our employees are clear on how to raise safeguarding concerns about how colleagues or people receiving our services are being treated, and/or about practices within our business or supply chain
- Raising Concerns Policy – We operate a Raising Concerns at Work policy, so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals.
- The Trusts’ approach to procurement and our supply chain includes:
- Ensuring that our suppliers are carefully selected through our robust supplier selection criteria/processes;
- Requiring that the main contractor provides details of its sub-contractor(s) to enable the Trust to check their credentials;
- Random requests that the main contractor provides details of its supply chain;
- Ensuring invitation to tender documents contain a clause on human rights issues;
- Ensuring invitation to tender documents also contain clauses giving the Trust the right to terminate a contract for failure to comply with labour laws;
- Using the standard Supplier Selection Questionnaire (SQ) that has been introduced (which includes a section on Modern Day Slavery).
Staff within the Trust must contact and work with the pcurement department when looking to work with new suppliers to ensure appropriate checks can be undertaken.
Where it is verified that a subcontractor has breached the child labour laws or human trafficking, then this subcontractor will be excluded in accordance with Regulation 57 of the Public Contracts Regulations 2015. The Trust will require that the main contractor finds a new subcontractor. The Trust operates zero tolerance to slavery and human trafficking and expects all direct and indirect suppliers/contractors to follow suit.