Introduction

Health Choices Global Limited “Health Choices Global” recognises that all businesses have an obligation to prevent slavery and human trafficking and will do all in its power to prevent slavery and human trafficking within its business and within the supply chains through which it operates.

Modern slavery can take many forms including the trafficking of people, forced labour, servitude and slavery. As recruitment experts, we take our responsibility for supplying staff extremely seriously and are aware of the potential for being targeted by traffickers and unlicensed gangmasters. Our own processes around candidate engagement ensure our employees are alert to the signs of exploitation, in order that we may take the necessary action promptly and effectively should it be identified.

This statement focuses specifically on Health Choices Global compliance with the Modern Slavery Act 2015 (the Act) and highlights the steps we take to ensure there is no slavery or human trafficking occurring within the organisation or its supply chains. One of our Company’s most valuable assets has always been its reputation for integrity and fairness. Maintaining this reputation within our market is an essential pre-requisite to our continued success.

This statement sets out Health Choices Global’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2021 to 31 March 2022.

As part of the healthcare sector and recruitment industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.
Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking

Organisation’s Structure

Health Choices Global grow and diversify the markets we serve by recruiting and retaining the best people, empowering them with innovative technology solutions. Our aim is to be the first-choice partner for health, life sciences and social care professionals and providers, across the globe. Our solutions are delivered through three segments: specialised staffing, workforce management solutions, Training and health and social care services.

In line with the Health Choices Global values of People are at the centre of all we do, Driving Care, Security and Excellence in the healthcare sector and recruitment industry, we recognise that we have a strong responsibility to take a robust approach to slavery and human trafficking. We will not tolerate slavery and human trafficking in our business or supply chain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that any form of slavery is not taking place in our own business or supply chains.

Whilst we assess the risk of modern slavery as low in our supply chain, we have taken appropriate steps to ensure our procedures are appropriate by:

• Ensuring robust recruitment procedures which include immigration checks
• Ensuring employees and Temporary Workers have the correct right to work status and documents
• Confirming that appropriate clearing is obtained (e.g. DBS, PVG, Access NI)
• Ensuring employees and Temporary Workers are appropriately trained
• Strong policies and procedures for the business overall are in place

Our business and livelihood depend upon our customers. Every employee is responsible for ensuring that any contact with our customers and the public at large reflects professionalism, efficiency and honesty. We constantly strive to provide a ‘Best Value’ high quality service:

• We shall uphold the values of honesty, partnership and fairness in our relationships with stakeholders
• We shall ensure a high level of business performance while minimising and effectively managing risk
• We shall strive to provide continuous improvement in terms of service quality and cost
• We will register and resolve customer complaints in accordance with our standards of service.
• We will deal fairly with Temporary Workers and suppliers in our supply chain.
• We will not create barriers to the use of small and medium-sized enterprises who are qualified to provide goods or services, and we will encourage innovation in our supply chains to increase the value or quality of supply.
• We will be fair and reasonable in our payment practices.

Our Supply Chains

Our supply chains include, but are not limited to, sourcing candidates for clients. This may involve the introduction by external agencies to Health Choices Global of candidates for onward supply to our clients. We expect our suppliers and potential suppliers to aim for high ethical standards and to operate in an ethical, legally-compliant and professional manner by adhering to our Supplier Code of Conduct. We also expect our suppliers to promote similar standards in their own supply chain.

Our Policies including on Slavery and Human Trafficking

Suppliers are expected to adhere to our Supplier Code of Conduct, which includes specific reference to the Modern Slavery Act 2015, and should have in place a policy recognising, respecting and protecting the human rights of their employees, those of their suppliers and business partners and the communities affected by the suppliers’ operations.

• Employees should be free to choose to work for their employer and to leave the company upon reasonable notice.
• All employees must be provided with a clear contract of employment, which complies with local legislation.
• All employees must be treated in a fair and equal manner and with dignity and respect.
• Any form of discrimination, victimisation or harassment on any grounds including, but not limited to, marital or civil partnership status, sex (including gender reassignment), race (including colour, ethnic and national origin, nationality), disability, sexual orientation, having or not having dependants, religious belief or political opinion, age, trade union activity and offending background should be prohibited.
• All applicable laws and industry standards on employee wages, benefits, working hours and minimum age should be adhered to in all countries of operation, without any unauthorised deductions. Suppliers should observe the provisions of the International Labour Organization such that any young persons under the age of 18 should not be employed to work at night or for any hazardous work and their employment should not harm the young person’s education, health or physical, mental, moral or social development. No young persons may be employed below the age of 16.

All slavery and human trafficking laws must be complied with including, but not limited to, the UK Modern Slavery Act 2015. Suppliers must ensure their business operations are free from slavery and human trafficking practices whether in the UK or elsewhere, both internally and within their supply chains and other external business relationships. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

Due Diligence Process for Slavery and Human Trafficking

Health Choices Global ensure strict compliance checks are carried for all candidates it supplies. We verify the identity of each worker and their right to work before supply commences.

As part of our commitment to identify and eradicate slavery and human trafficking, we have in place a process to undertake due diligence on our supply chain network to ensure compliance with legislative obligations; such compliance forms part of our contractual relationship with suppliers.

All Health Choices Global employees have access to dedicated channels through which they may voice concerns, either through local reporting mechanisms or through the global whistleblowing procedure. Health Choices Global is committed to protecting employees when disclosing malpractice and will ensure that all disclosures made in good faith will be treated confidentially and without fear of retaliation.

Training

All staff within Health Choices Global are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty. A training module on modern slavery and human trafficking is also available to all employees. In the UK, an e-learning module forms part of a training package undertaken by new employees. Should any of our colleagues need any additional information or support with regard to human trafficking, forced labour, servitude and slavery this will be provided.

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

• Policies: The Senior Leadership Team are responsible for the policy management, control and administration of the policy development process which includes: maintaining a central register of all policies, ensuring policies are reviewed in a timely manner, ensuring consistency through the policy development process, archiving superseded policies onto Health Choices Global Group Pages and removing superseded policies.
• Investigations/due diligence: Health Choices Global adopts a transparent approach to the recruitment and placement of our candidates and employees, and fully complies with the Duty of Candour principles, and the Modern Slavery Act 2015. Health Choices Global has robust contracts and/or service level agreements with all supply chains which promote transparency between both parties. Any incidents of Modern Slavery and/or Human Trafficking are documented, investigated (if appropriate) and referred appropriately to the regulatory bodies in accordance with the Health Choices Groups Incidents Policy/Procedure and in line with the Modern Slavery Act 2015.
• Whistleblowing: Health Choices Global has an independent whistleblowing hotline that employees can access if they suspect modern slavery is taking place.
• Training: All Health Choices Global employees complete a Modern Slavery training module at the start of their employment. Refresher training will be applicable for all Health Choices Global employees regularly thereafter.

Relevant policies

These policies include warning signs and reporting/escalation processes. Other policies and procedures that further support the identification and management of Modern Slavery and Human Trafficking are:

• Whistleblowing for Internal Employees Policy
• Whistleblowing for Associate Workers and External Partners Policy
• Equality, Diversity and Human Rights Policy
• Corporate Responsibility Policy
• Complaints Policy
• Safeguarding Children Policy
• Safeguarding Vulnerable Adults Policy
• Recruitment and Selection Policy

Performance indicators

We have reviewed our key performance indicators (KPIs). As a result, we are:

• Continuing to review our policies and procedures to ensure that any form of slavery is not happening in our own business or supply chains.
• Ensuring robust recruitment procedures which include immigration checks are in place.
• Ensuring employees and Temporary Workers have the correct right to work status and documents.
• Confirming that appropriate clearing is obtained (DBS, PVG, Access NI).
• Ensuring employees and Temporary Workers are appropriately trained.
• Requiring all Health Choices Global employees to complete modern slavery training.

Approved by the Senior Leadership of Health Choices Global on 15 July 2021

To obtain a signed copy of this statement please email our team at hello@healthchoicesglobal.com.