2024 Modern Slavery and Human Trafficking Statement

Introduction

gtd healthcare (gtd) is driven by our vison to improve the health and quality of life of our diverse population through our values of:

  • putting patients first;
  • looking after our people;
  • contributing to the well-being of our local communities.

gtd has zero tolerance to slavery and human trafficking and we are committed to ensuring that there is no modern slavery or human trafficking in any part of our services or supply chains. We recognise our continued responsibility to address and mitigate the risk of modern slavery and human trafficking and the need to implement effective systems and controls. This statement sets out our commitment and actions taken to do our part to eradicate these abhorrent practices and meet the requirements of the UK Modern Slavery Act 2015.

By publishing this statement, we believe we are demonstrating not only our pledge to the principles of the Modern Slavery Act; but also, our commitment to operate in ways that are compatible with the Human Rights Act 1998, including the right for people to be free from slavery and forced labour. We are working to make sure we are caring and protecting the communities we serve from the impact of modern slavery.

Structure, business and supply chains

gtd is a not-for profit organisation providing primary care services over a wide geographical footprint across the following Integrated Care Boards; Greater Manchester, Lancashire and South Cumbria and Cheshire and Merseyside. We provide a range of scheduled and urgent primary care services such as GP practices, urgent care centres, GP out-of-hours services and a range of specialist services such as migrant health and Special Allocation Schemes. Our main supply chains are for consumables and drugs to enable delivery of direct patient care and clinical staff via agencies.

We have a strict set of ethical values that we use as guidance with regard to our commercial activities. We therefore expect that all our suppliers to adhere to the same ethical principles.

We oppose the exploitation of workers through any form of forced or bonded labour, slavery, human trafficking or other labour practices that involve harsh or inhumane treatment. We strive to ensure that slavery and human trafficking is not taking place within any of our supply chain business partners and will not tolerate such activities. Therefore, we require our suppliers to comply with these principles and share them with any subcontractors they may use.

Policies

We believe that it is the responsibility of every employee to help ensure all of our activities meet our high standards for behaviour and business ethics and established accountability for compliance with law and policy.

The organisation promotes the need for open dialogue about potential violations and concerns and provides confidential reporting methods through our director of governance, and Freedom to Speak Up Guardians.

With regard to our own practices/services, we set standards for a diverse workplace that provides a safe and healthy environment and complies with or exceeds local law. gtd requires an effective programme to be in place to help ensure compliance with labour laws involving migrant and foreign national workers.

Our People’s Services policies and procedures provide processes to ensure that our employees and those employed in our supply chain are always treated fairly. These include:

  • confirming the identities of all new employees, including those engaged via agencies, and their right to legally work in the United Kingdom and appointing staff subject to references, immigration checks and identity checks.
  • ensuring staff are paid a fair wage; we are a Real Living Wage employer paying all staff a rate of pay above the national living wage that allows them to meet their everyday needs.
  • providing guidance and induction to all managers to ensure they are always aware of, and comply with, current employment legislation.
  • our Whistleblowing policy gives a platform for employees to raise concerns.

Due diligence processes

We review all business partners/suppliers and request confirmation from our key suppliers that they are compliant with the act.

We will continually review the employment or human rights contract clauses in supplier contracts. We will assess any instances of non-compliance with the act on a case-by-case basis and will then tailor remedial action appropriately.

Assessing the risks

We do this by supply chain mapping and developing risk-ratings on the labour practices of our suppliers to understand which markets are most vulnerable to slavery risk.

Effectiveness and performance indicators/monitoring

We recognise that the risks from modern-day slavery change, and as such our approach to preventing modern-day slavery will be reviewed annually by our executive management team. This approach will monitor and review:

  • effectiveness of our risk assessment processes;
  • staff training programmes;
  • reporting and escalation processes.

Training

Our patients are a key priority. We are committed to ensuring that our employees are aware of the Modern Slavery Act 2015 and they understand their safeguarding duty to protect and prevent any further harm and abuse when it is identified or suspected that an individual may be or is at risk of modern slavery/human trafficking.

  • To increase awareness of the issues and how staff should tackle them, we provide access to internal and external training for gtd staff through our safeguarding team and gtd academy. We will continue to develop our training resources in-line with best practice.

Director’s declaration

This statement is made pursuant to the relevant legal requirements of the United Kingdom and will be reviewed on an annual basis. It is signed by gtd’s chief executive officer on behalf of the gtd healthcare Board.

David Beckett updated.jpg

David Beckett
Chief Executive Officer