2018 Modern Slavery and Human Trafficking Statement


Mid Hampshire Healthcare continues to recognize its responsibility to address and mitigate the risk of modern slavery and human trafficking in its operations. This statement sets out our commitment and actions taken to do our part to eradicate these abhorrent practices, as well as meet the requirements of the UK Modern Slavery Act 2015 and the California Transparency Act.  


Structure, Business & Supply Chains

All staff that we employ are aware of their rights and responsibilities. Recognizing the important need to respond to the modern slavery crisis, we have also requested assurances from our suppliers to ensure that they too are aware of their responsibilities. Our patients are a high priority and all staff have received some training around identifying and dealing with those who may have been involved in modern slavery and human trafficking.



We will also 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. 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 establishes accountability for compliance with law and policy.
We believe our training addresses the need for open dialogue about potential violations and concerns, and provides confidential reporting methods through our Clinical Director and Caldicott Guardian. Where required we have access to translation services through the Big Word.

We completely 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.  Therefore we require our suppliers to comply with these principles and to share them with any subcontractors they may use. Each site is responsible for implementation of this requirement and annual confirmation that it has taken place.
With regard to our own member practices, we set standards for a diverse workplace that provides a safe and healthy environment and that complies with or exceeds local law. Mid Hampshire Healthcare requires an effective programme be in place to help ensure compliance with labour laws involving migrant and foreign national workers.


Due Diligence Processes

We review all business partners. These reviews include a check for either a compliance statement and a check whether adverse media, where modern slavery issues can and in fact have been found. Of course, simple termination of a contract relationship may not always be the most appropriate response based on circumstances, so substantive findings of adverse media about a business partner are handled on a case-by-case basis, according to the circumstances. A working group wpuld be setup to assess the company’s risk of exposure to these practices and additional activities to help mitigate any risks.  


Training and Awareness

Modern slavery and human trafficking training is provided via Bluestream Elearning and all staff are required to undertake this training at least every 24 months.


Effectiveness and Performance Indicators/Monitoring

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

  • Effectiveness of risk assessment processes
  • Staff training programs
  • Assessment programs (where applicable); and
  • Reporting and escalation processes.

This statement is made pursuant to the relevant legal requirements of the United Kingdom.

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