Modern Slavery Act Statement
Who we are
This statement is made in relation to the Virgin Care Group’s supply chain and on behalf of Virgin Care Limited and Virgin Care Services Limited (“The Virgin Care Group”).
Virgin Group has invested more than £75m of funding into the business since taking it on, allowing it to deliver innovative and transformative services for the public. Sir Richard Branson has pledged to reinvest any profits made by the organisation in the future which he could take as a dividend (over and above his original investment) back into publicly funded health and care services.
The Virgin Care Group provides more than 400 frontline health and social care services, partnering with the National Health Service and local authorities across England. The organisation employs approximately 7,000 people.
As a result, each year our organisation evolves with the end of some contracts and the start of new contracts involving the transfer of operational health and care services. Consequently, new suppliers, supply chains and ways of working are inherited along with those contracts which naturally affect our progress, in proportional terms, in this statement.
Our supply chains
Our supply chain includes professional services providers, NHS Trusts, NHS Foundation Trusts, social enterprises, medical equipment suppliers and office equipment suppliers. As a consequence of the nature of our business the vast majority of spend is on medical consumables; around 50% of our annual procurement spend is with NHS Supply Chain Limited, a company owned by the UK Government’s Secretary of State for Health and Social Care, and more than 99% is with companies based in the UK and Europe.
We share the majority of our supply chain with the state-operated NHS, and all organisations supplying the NHS are subject to the NHS Code of Conduct on Ethics and Labour, which includes aspects looking at preventing modern slavery. As an NHS supplier ourselves, we are also subject to this code. We are aware that in 2021, the Department of Health and Social Care will publish a Modern Slavery Statement which will include details of the measures being taken through the NHS Supply Chain and we will review this as part of our revised statement.
While a very small proportion of spend, from time to time we procure marketing collateral including ‘promotional items’ where these are appropriate for the delivery of our services. These are always sourced from British Promotional Merchandise Association Chartered (http://bpma.co.uk/) suppliers, ensuring appropriate standards of employment and wages are upheld. During 19-20 we took additional steps to reduce the usage of promotional materials across the Group, limiting the product range available only to eco-friendly and sustainable items and requiring colleagues to demonstrate a return on the investment in items.
We consider that modern slavery and human trafficking are completely unacceptable whether they are in our supply chain or any other part of our business, and the communities where we work. We regularly review our policies and procedures in order to ensure we have effective systems which lessen the risk of modern slavery and human trafficking taking place anywhere in our supply chains.
We have anti-slavery and trafficking provisions contained within our procurement policy which set out our approach to ensuring our supply chain does not contain modern slavery and our Safeguarding and Whistleblowing policies provide colleagues with guidance on how to report their concerns.
Where annual spend with an individual supplier exceeds £50,000, or a supplier has been identified through initial due diligence as being high risk, we work to ensure Virgin Care standard Terms and Conditions – which contain provisions ensuring compliance with our policy on Modern Slavery – are in place rather than the supplier’s own terms.
We encourage and require our suppliers to proactively manage the risk of modern slavery in their own supply chains.
Our frontline teams are trained to an appropriate level in Safeguarding for their role, and this training – which must be completed annually – includes material on identifying the signs of modern slavery and human trafficking among the people who use the services we run.
In 19-20, 88% of our colleagues completed the appropriate safeguarding training which is due every three years within the relevant timeframes, an increase of 1% year-on-year. We continue to review compliance through our annual appraisal process and to promote the importance of safeguarding knowledge.
In addition, we take part in a number of joint initiatives with local authorities and other healthcare providers to further increase our ability to identify potential modern slavery and human trafficking among our patient populations.
Our central procurement team
Our procurement team use the Ethical Trade Initiative (ETI) Base Code as our standard on Labour, and all members of the team are required to certify that they are familiar with the code on an annual basis. Each member of the team has confirmed that this has been completed during 19-20.
All members of the team will be required to complete eLearning training which reinforces both our policy and the ETI Base Code, part of our annual Statutory and Mandatory Training Programme.
In 20-21, we will review the new ETI Modern Slavery Statement Framework as we produce our statement after it will have been published.
As part of the delivery of health and care services, we employ the services of sub-contractors including cleaning, driving and delivery services which may be considered at high risk of modern slavery. These suppliers are expected to comply with our standard Terms and Conditions, including provisions preventing modern slavery. Over the coming year, we plan to review our processes for managing these types of sub-contractors.
Training our colleagues
We offer a range of guidance and training to all of our colleagues in the business on our Purchase to Pay system, best practice procurement and assisting with minimising the risk of modern slavery in our supply chains.
Since our last statement, each of our Business Units has been partnered with a Procurement Business Partner to support, among other things, procurement training and development. During the year, we began a programme of regular refresher training across our services covering all aspects of our Purchase to Pay function.
Due diligence processes
We seek to minimise the number of suppliers we work with in order to allow us to work more closely with those we do. The addition of new suppliers to our system is managed by the Procurement team in line with our policies, and our process was enhanced in 2019 with additional checks and information collected.
Our central procurement team ensure that all our suppliers are aware of our policy and our Terms and Conditions. Since 2017, all new suppliers have been required to confirm they have read, understood and comply with our Terms and Conditions, which cover labour issues, and complete a questionnaire covering their policies in risk areas including slavery and human trafficking before they are accepted as a supplier.
In 20-21, we will publish our Terms and Conditions with regard to modern slavery on our website alongside our Modern Slavery Statement.
Under our revised approach to contract management, we have identified our key list of critical suppliers and we undertake a robust due diligence process of those suppliers’ ongoing compliance with our Standard Terms and Conditions. This includes reviewing their business continuity, financial standing and adherence to policies and processes and ensuring their direct suppliers are also taking steps to minimise the risk of modern slavery in their business and supply chain.
In 2019-20, we widened this due diligence to survey each of our suppliers with an annual spend of £50,000 or greater and will continue this.
In 2019-20, we aimed to audit 100% of new suppliers added as a result of new contracts and kept on as suppliers.
For practical reasons, we excluded sole traders and small LLPs who supply the services of one or a small number of consultants or doctors from this audit process. Our processes were independently audited by the company auditors as part of the annual audit process and no concerns were raised.
During 20-21, we will review our end to end ‘purchase to pay’ (p2p) system and streamline our supplier database. This will ensure we continue to have as few suppliers as possible, helping us to enhance our partnerships with our core group of suppliers. This will improve our understanding of their business and further assure us of their work around modern slavery and safeguarding.
If we find an existing supplier is non-compliant with our policies or code of conduct, or provides us with inadequate information to assure us of their compliance with our Terms and Conditions we will work with them to ensure that they are able to provide us with the information and, if appropriate, to improve their performance.
If a supplier is found to be unable to meet our Terms and Conditions or policies, we will review our relationship with them as soon as practicable. During 2019-20, we are pleased that we did not encounter any occasions where we needed to consider terminating a relationship.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the Virgin Care Group’s slavery and human trafficking statement for the financial year ending March 31 2020.