Modern Slavery Act Statement
We are committed to the prevention of modern slavery and human trafficking in all its forms, and will not tolerate or condone the abuse of human rights. We have a zero-tolerance approach to slavery and human trafficking, which extends to all of our business dealings and transactions.
This statement is made by Virgin Healthcare Holdings Limited whose ultimate parent company is Virgin Group Holdings Limited (a company incorporated in the British Virgin Islands which is wholly owned by Sir Richard Branson).
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”).
The Virgin Care Group provides more than 400 frontline health and social care services, predominantly on behalf of the National Health Service and on behalf of Local Authorities across the country. The organisation employs approximately 7,000 people.
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 80% of our annual procurement spend is with NHS Supply Chain, a Government-commissioned supplier service, 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 subjectto the NHS Code of Conduct on Ethics and Labour. As an NHS supplier ourselves, we are also subject tothis code.
While a very small proportion of spend, from time to time we procure marketing collateral including t-shirts, pens, caps and ‘promotional items’. These are always sourced from British Promotional Merchandise Association Chartered (www.bpma.co.uk/) suppliers.
We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business. Weregularly 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 supplychains.
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 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.
In 2018-19, 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 addition, senior procurement officers are members of the Chartered Institute of Purchasing and Supply and have completed that organisation’s Ethical Procurement and Supply course.
Training our colleagues
We have continued our work on the ETI and Department of Health and Social Care Ethical Procurement for Health programme throughout the year.
During 2018-19, we will introduce training for colleagues using our Purchase to Pay system across the organisation. This will raise awareness of the need to ensure suppliers meet our Modern Slavery policies prior to formal due diligence being undertakenby the procurement team.
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.
Our central procurement team ensure that all of our suppliers are aware of our policy and our terms and conditions. From 2017-18 all new suppliers must 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.
We also undertake regular risk assessment of existing suppliers to understand and mitigate risks as part of our contract management, led by our central procurement team.
During 2018-19, we will survey our existing suppliers under the new process introduced in 2017-18. We will aim to survey 10% of our suppliers, and to achieve full compliance among 100% of those surveyed.
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 consider terminating our relationship with them as soon as practicable.
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 2018.
For and on behalf of
VIRGIN CARE LIMITED,
VIRGIN CARE SERVICES LIMITED