Slavery and Human Trafficking Policy Statement

Organisational Structure

The Company is controlled by a Board of Directors. The Company’s Head Office is located in Bolton.

Healthya is predominately involved in the provision of Staff for the primary care, NHS and the private sector via an APP, Information systems and face to face consultancy formats. It offers a 24 hour On-call service for which demand is consistent throughout the year

Definitions

Healthya considers that modern slavery encompasses:

  • Human trafficking;
  • Anti-slavery;
  • Child labour and inhumane treatment;
  • 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 movement.

Commitment

Healthya acknowledges its responsibilities under the Modern Slavery Act 2015 and is committed to preventing slavery and human trafficking, child labour and inhumane treatment within its own businesses and in its supply chains. Healthya understands that this requires an ongoing review of both its internal practices in relation to its labour force and its supply chains.

Healthya has a zero-tolerance policy towards modern slavery. It will refrain from entering into business, and/or will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

The labour supplied to Healthya in pursuance of the services it provides is carried out wholly in the countries where those services are provided i.e. United Kingdom, and as appropriate.

No labour provided to Healthya in the pursuance of the provision of its own services is obtained by means of slavery, human trafficking, child labour or inhumane treatment . Healthya strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom as appropriate, and in many cases exceeds those minimums in relation to its employees.

Healthya offers employment contracts on a guaranteed hours basis only; no offers of employment are made on a zero hours basis.

Part-time and fixed-term employees within Healthya are provided with the same pro-rata contractual entitlements as full-time and permanent employees. If these are not offered, Healthya is able to rely on objectively justifiable grounds.

Healthya employees are offered a competitive remuneration package and Healthya prides itself on the additional benefits it is able to offer its employees on a wide variety of platforms. It conducts annual staff surveys on an anonymous basis to give employees a voice on their individual employment, their department and Healthya as appropriate. Commitment to creating career progression in a supportive environment has been rewarded by high placing for Healthya in well regarded “Best Places to Work” awards.

Potential Exposure

Healthya considers its exposure to modern slavery to be limited. Nonetheless, it has taken steps to ensure that such organisations do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

In the operation of its business, Healthya’s main supply chains are those related to the provision of services. Healthya considers its main exposure to the risk of slavery, human trafficking, child labour and inhumane treatment to exist in its supply chains.

Steps

Healthya carries out due diligence processes in relation to ensuring slavery, human trafficking, child labour or inhumane treatment does not take place in its supply chains.

Healthya has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with slavery, human trafficking, child labour or inhumane treatment.

In accordance with section 54(4) of the Modern Slavery Act 2015, Healthya has contacted (or attempted to contact) all first-tier suppliers to set out our zero-tolerance stance on modern slavery and to ensure that slavery, human trafficking, child labour or inhumane treatment is not taking place.

Healthya has taken action to monitor reports of modern slavery and will cross reference such reports with our firsttier supply chain. Healthya will seek to discontinue business with any first-tier supplier found by the enforcement authorities to be involved in modern slavery.

Healthya encourages use of its whistleblowing policy to report any concerns regarding modern slavery and will investigate any complaints thoroughly.

Training

Upon commencement of employment, all employees undergo a structured classroom environment induction process. All employees are made aware of the policies relating to standards of behaviour that it requires from them. Healthya will ensure that 100% of new starters will complete the induction within two weeks of commencement of employment.

Healthya also provides training on awareness of modern slavery to those within the business who have been identified as having responsibilities in this regard. Healthya will ensure that annual update training is provided.

Assessment of Effectiveness on Combatting Modern Slavery

To ensure effectiveness in combatting modern slavery, Healthya maintains an accurate supplier list including contact details. It will ensure action is taken in response to reports of modern slavery in its supply chains and any complaints made via the whistleblowing policy will be responded to in accordance with the policy.

There have been no reports that any of Healthya suppliers have been involved in activities covered by the Modern Slavery Act.

Policies

Healthya also has a Corporate Social Responsibility Policy which further defines its stance on modern slavery. In addition, a Whistleblowing policy is in place which encourages the reporting of any wrongdoing which is in the public interest.

Business Compliance Manager

Healthya has a Business Compliance Officer, to whom all concerns regarding modern slavery should be addressed. The Compliance Manager will undertake an annual review of Healthya obligations towards eradicating modern slavery within its organisation and supply chains.

Review

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and applies to all companies within and associated to the Healthya. It is reviewed for each financial year.

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