Modern Slavery Act 2015
Policy
WNA Healthcare (WNA) are committed to opposing modern slavery, human trafficking and exploitation in all formats and preventing it, where possible. In cases where this has been identified, WNA & HMR will do all it can to ensure victims are supported and directed to the relevant channels for support.
The Modern Slavery Act 2015 is a legislative framework within the UK to identify victims and prosecute offenders. The key provisions include the Definition of Modern Slavery, Duty to Notify (public authorities to notify NCA National Crime Agency and Victim support through the NRM National Referral Mechanism (this allows Frontline professionals to refer suspected victims of modern slavery via Identification, Referral process, Assessment and Support Services) .
What exactly is this?
Definitions of slavery, human trafficking and exploitation:
- Slavery is behaviour depriving a person of their freedom and property
- Human trafficking is arranging or facilitating the travel of one persons view to them being exploited even if there is consent to travel
- Exploitation is forced or compulsory labour which can include direct threats of violence
Guidelines
WNA have a number of ways to ensure the policy remains part of the companys core values and expect our staff, customers and suppliers to follow these values as well. To prevent opportunities for modern slavery we actively look to do the following:
- be transparent in our business activities throughout the supply chain and disclose any obligations under the Act.
- seeking transparency from our suppliers, clients, staff and contractors
- all staff are aware of their obligations to help prevent and identify modern slavery by carrying out business in a way as to eradicate any opportunity of modern slavery.
Policy
1. WNA are committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
2. WNA are committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.
3.
WNA provides appropriate training and awareness information for all
of its staff. In particular:
* All
of our staff receives 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.
- To trust and act on professional instinct that something is not quite right e.g. through a combination of triggers like an inconsistent story and a pattern of symptoms that may cause suspicion of trafficking.
- All of our staff receives 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.
- Be aware that trafficked people may not self-identify as victims of modern slavery or can be prevented from revealing this for fear of shame, language barriers and a lack of opportunity to do so.
- Some victims may not open up as they do not feel safe to do so or it may take time to feel safe enough to open up.
- Try to speak to the victim in private and to reassure them whilst not making any promises or asking any judgemental questions.
- Challenge any cultural beliefs which may stand in the way of making an informed decision
- Some signs of trafficking to look out for include if the victim is always accompanied by someone controlling, appears to be withdrawn and submissive, has old or serious injuries, gives vague information to explain events, is not registered e.g. with a GP, has experience of being moved around different locations, struggles to speak English, has no documents or suspicious looking documents.
- Victims of modern slavery may someone only become apparent through health issues such as sexually transmitted diseases, evidence of self-harm, fatigue, injuries, trauma mental, physical and sexual, psychiatric and psychological distress, pregnancy and non-specific symptoms.
4. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to [identify an appropriate contact(s), by name or by role].
5. Reports surrounding these issues are taken extremely seriously by our Directors who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:
- Working with the appropriate organisations to improve standards,
- Removing that organisation from our preferred supplier list,
- Passing details to appropriate law enforcement bodies.
6. We regularly monitor our risks in this area through the use of relevant key performance indicators, including:
- The percentage of candidates supplied from audited businesses and/or 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, and
- The level of modern slavery training and awareness amongst our staff.
7. As part of our efforts in this area, we publish a modern slavery statement on an annual basis.
8. We would also recommend reading this in conjunction with our other policies, including our:
- Anti-Fraud, Anti-Theft and Anti- Corruption Policy
- Whistleblowing policy
- Recruitment Policy
9. The Department of Health runs a Modern Slavery programme, and the material draws expertise from across the health sector and non-governmental organisations with victims of trafficking. The elearning resource was produced by Platform 51 in partnership with the Department of Health and guidance from the following representatives:
- Royal College of Paediatrics and Child Health
- British Association of Sexual Health and HIV
- Royal College of Psychiatrists
- Home Office
- ECPAT UK
- UK Human Trafficking Centre, Serious Organised Crime Agency
- Ministry of Justice
- National Child Trafficking Advice Centre, NSPCC
- Salvation Army
- Poppy Project
- Section for Womens Health
- Institute of Psychiatry, Kings College London
- Department of Health
- the Home Office (including UK Border Force, UK Visas and Immigration, and Immigration Enforcement)
- Local authorities
- Health and Social Care Trusts (HSC Trusts)
- Police
- POPPY Project
- National Crime Agency (NCA)
- Trafficking Awareness Raising Alliance (TARA)
- Migrant Help
- Kalayaan
- Gangmasters and Labour Abuse Authority
- Medaille Trust
- Salvation Army
- Barnardos
- National Society for the Prevention of Cruelty to Children (NSPCC).
- Unseen UK
- New Pathways
- BAWSOs
- Refugee Council
The link below is designed for Frontline Healthcare workers to identify victims of modern slavery and to take action to address their health and safety needs.
To report modern slavery, the hotline number to use is 0800 0121 700 or this can be reported online at:
Designated organisations classed as first responders to help provide victims of modern slavery with support are:
- the Home Office (including UK Border Force, UK Visas and Immigration, and Immigration Enforcement)
- Local authorities
- Health and Social Care Trusts (HSC Trusts)
- Police
- POPPY Project
- National Crime Agency (NCA)
- Trafficking Awareness Raising Alliance (TARA)
- Migrant Help
- Kalayaan
- Gangmasters and Labour Abuse Authority
- Medaille Trust
- Salvation Army
- Barnardos
- National Society for the Prevention of Cruelty to Children (NSPCC).
- Unseen UK
- New Pathways
- BAWSOs
- Refugee Council
This policy was adopted on 6th April 2015 after being agreed by the company Directors of WNA & HMR. It is reviewed on an annual basis. As the company does not meet the total turnover threshold of £36m or more, it does not publish a annual statement.
