This statement is made as part of Charterhouse Medical UK’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Charterhouse Medical UK operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.
This statement is published in accordance with section 54 of the Act, and relates to the financial year April 2019 to March 2020. It was approved by Charterhouse Medical UK on 1st September 2019
Charterhouse Medical UK is a limited company operating in the recruitment sector. We provide introduction services, supply temporary workers, act as a neutral vendor, and act as a master vendor in the Medical Healthcare sectors
Charterhouse Medical UK is part of the wider Charterhouse group. For details of our group structure, see https://www.charterhouse.com.au/
Who we work with
All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff. All of the temporary workers we supply are identified by our staff. Some of these work-seekers operate through their own limited companies. We do not supply work-seekers to hiring companies through any intermediaries. Some of our work-seekers are supplied via other businesses, who facilitate providing them to the eventual hiring company.
As a “neutral vendor”, we work with other businesses to supply workers to hiring companies. All of the workers we supply are hired directly by other businesses, and we facilitate supplying them to the hiring companies. Some of these workers operate through their own limited companies.
As a “master vendor”, we work with other businesses to supply workers to hiring companies. We hire some of the workers directly, who are directly recruited by our staff. Other workers are hired directly by other businesses. Some of these workers operate through their own limited companies. We facilitate supplying a mix of these workers to the hiring companies.
The hiring companies that we work with are located in England. The work-seekers / workers we supply live in various locations.
As part of our business, we also work with the following organisations:
- NHS Employers
- the Recruitment and Employment Confederation (www.rec.uk.com) and the Institute of Recruitment Professionals (www.rec-irp.uk.com)
Charterhouse Medical UK has a modern slavery policy www.charterhousemedical.co.uk/anti-slavery-policy
In addition, Charterhouse Medical UK has the following policies which incorporate ethical standards for our staff and our suppliers.
Policy development and review
Charterhouse Medical UK’s policies are established by our directors and our senior leadership team, based on advice from HR professionals, industry best practice and legal advice, and in consultation with REC. We review our policies on a regular basis, or as needed to adapt to changes.
Our Processes for Managing Risk
In order to assess the risk of modern slavery, we use the following processes with our suppliers:
- When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
- We conduct audits before entering into a commercial relationship with any business where there is the potential for risk. These audited businesses form the basis of our preferred supplier list.
- We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.
After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.
Additionally, we have taken the following steps to minimise the possibility of any problems:
- We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
- We require the businesses we work with to abide by our code of supplier conduct / address modern slavery concerns in their policies / publish a modern slavery statement
- We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
- Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
- We ensure that all of our suppliers are members of appropriate industry bodies and working groups.
Our staff are encouraged to bring any concerns they have to the attention of management.
As part of monitoring the performance of Charterhouse Medical UK, we track the following general key performance indicators:
- The level of training amongst your staff,
- The speed with which you investigate related complaints, and the effectiveness of any whistle-blowing procedures, and/or
- The level of compliance and transparency you have established in your supply chain.
Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our board of directors and our senior leadership staff:
- the percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements
- the percentage of workers and candidates supplied from audited businesses / our preferred supplier list
- the effectiveness of enforcement against suppliers who breach policies
- the amount of time spent on audits, re-audits, spot checks, and related due diligence
- the level of modern slavery training and awareness amongst our staff
We benchmark our indicators against industry best-practice, discuss our indicators with suppliers and carefully consider our indicators, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.
All of our staff receive training and support that is appropriate to their role. In particular:
- Our leadership team and senior supply chain managers receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
- Our recruiters, HR personnel, and staff involved in our procurement and supply chains undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
- All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
As part of this, our staff are encouraged to discuss any concerns that they have.
Training is refreshed regularly.