Modern Slavery

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

At Divine Healthcare Solutions Limited we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2023.

Our Business Structure and Supply Chains

Divine healthcare Solutions Limited has business operations in the United Kingdom. We work with direct suppliers who provide us with services such as domiciliary and care services from the local authorities and private clients. For more information about our company, please visit our website: www.divinehealthcaresolutions.co.uk

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.

We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

Policies  

Divine Healthcare Solutions Limited operates the following policies for identifying and preventing slavery and human trafficking in our operations:

Whistleblowing Policy

We encourage all employees, customers, and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers. We operate this policy so that employees can raise concerns about how staff are being treated or practices within our business or our supply chains without fear of reprisal.

Code of Conduct

Our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

Recruitment and selection policy

Divine Healthcare Solutions conduct checks on all prospective employees to verify that they are eligible to work in the UK. Certain roles require a Disclosure and Barring Service (DBS) check where employees may be working with vulnerable people.

Safeguarding Policy

This policy highlights the potential risks of modern slavery and human trafficking, including how to identify signs of exploitation and how to report concerns.

Supplier due diligence

Divine Healthcare Solutions Limited undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Divine Healthcare Solutions Limited’s due diligence process includes:

• Building long-standing relationships with suppliers
• making clear our expectations of business partners
• evaluating the modern slavery and human trafficking risks of each new supplier and invoking sanctions against suppliers that fail to improve their performance.
• Assessing risks in the provision of services
• Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
• Requiring improvements to substandard employment practices
• Sanctioning suppliers that fail to improve their performance in line with our requirements

We require all suppliers to attest that:

• They don’t use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
• They don’t require employees to post a deposit/bond and don’t withhold their salaries for any reasons
• They don’t require employees to surrender their passports or work permits as a condition of employment

To ensure all those in our supply chain and contractors comply with our values, we have in place a standard clause in all our new agreements with suppliers and contractors which informs them of our commitment to combatting slavery and human trafficking and requires them to agree to this commitment when working with us. We are committed as a company to tackling modern slavery and human trafficking and want to work with suppliers who share this commitment.

Awareness
Divine Healthcare Solutions Limited has raised awareness of modern slavery issues by putting up posters across our facilities and sending an email that is focused specifically on modern slavery to all our staff, which explains:

• Our commitment in the fight against modern slavery
• Red flags for potential cases of slavery or human trafficking
• How employees should report suspicions of modern slavery

Training
In addition to the awareness programme, Divine Healthcare Solutions Limited has rolled out a fresh e-learning course to all employees and supplier contacts, which covers:

• Various forms of modern slavery in which people can be held and exploited
• The size of the problem and the risk to our organisation
• How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
• How employees should respond if they suspect slavery or human trafficking
• How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation
• What external help is available for the victims of slavery
• What terms and guidance should be provided to suppliers in relation to slavery policies and controls
• What steps Divine Healthcare Solutions Limited will take if a supplier fails to implement anti-slavery policies or controls
• An attestation from employees that they will abide by Divine Healthcare Solutions Limited’s anti-slavery policy

Measuring how we’re performing

Divine Healthcare Solutions Limited has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:

• How many employees have completed mandatory training?
• How many suppliers have filled out our ethics questionnaire?
• How many suppliers have rolled out an awareness and training programme that is equivalent to ours?
• How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues?
• What are the findings of our cross-functional Human Rights team, which reviews how we are addressing modern slavery and human trafficking?

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if: 
– No reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified. 

This statement covers 1 April 2023 to 31 March 2024 and has been approved by the board of Divine Healthcare Solutions Limited at the board meeting.