Modern Slavery Statement
July 2024
Introduction
This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by HCML for the period from the 1st April 2024 – 31st March 2025 to prevent modern slavery and human trafficking in its own business operations and supply chains.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. HCML has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
About the Organisation
HCML is a healthcare provider across a range of services covering health and wellbeing solutions, case management, injury rehabilitation, treatment services, occupational health, lifetime care and expert witness services to the personal injury, private medical insurance and corporate markets.
HCML employ almost 400 staff nationally.
The majority of our suppliers and service providers are based in the UK.
Our Policies on Slavery and Human Trafficking
HCML is aware of our responsibilities towards customers, clients, patients and employees and expect all our suppliers to adhere to the same ethical principles. 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. Our internal policies replicate our commitment to acting ethically and with integrity in all our business relationships. Currently all awarded suppliers sign up to our terms and conditions of contract which contain a provision to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains; and that they conduct their businesses in a manner that is consistent with HCML’s anti-slavery principles.
Relevant policies
HCML operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
- Recruitment Policy – We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all directly employed staff, and agencies on approved frameworks are vetted to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will
- Equality and Equal Opportunities Policy – We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities.
- Safeguarding Policies – We adhere to the principles inherent within both our safeguarding children and adult policies. These are compliant with legislation and provide clear guidance so that our employees are clear on how to raise safeguarding concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain.
- Whistleblowing Policy – We operate a whistleblowing 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.
- Supplier Code of Conduct – This code explains the manner, in which, we expect our suppliers to act.
Training
Advice and training about modern slavery and human trafficking is available to staff through our mandatory safeguarding children and adults training programmes, our safeguarding policies and procedures, and our safeguarding leads. It is also discussed at our compulsory staff induction training.
Regular staff training relating to this legislation will be provided to employees who sit within management or procurement functions.
We are looking at ways to continuously increase awareness within our organisation, and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business.
Our Performance Indicators
HCML aim to take the following steps over the course of the financial year ending March 2025:
- Requiring all staff to have completed training on modern slavery
- No reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
Board Approval
This statement has been approved by HCML’s CEO, Nick Delaney, who will review and update it annually.