MODERN SLAVERY POLICY.

Obsidian Healthcare Recruitment Limited (hereafter referred to as Obsidian Healthcare) recognises that all businesses have an obligation to prevent slavery and human trafficking and is committed to ensuring through all possible means to that this is prevented within its business and supply chains through which it operates. With Modern Slavery still taking place across the country, the Modern Slavery Act came into force on the 29th of October 2015 with the aim of seeking and eliminating the criminal act of slavery, human trafficking and forced labour.

Modern slavery can take many forms & the following definitions are encompassed within the term ‘modern slavery’ for the purposes of the Modern Slavery Act 2015;

‘Slavery’ is where ownership is exercised over a person.
‘Servitude’ involves the obligation to provide services imposed by coercion.
‘Forced or compulsory labour’ involves work or service extracted from any person under the menace of a penalty and for which the person has not offered himself voluntarily.
‘human trafficking’ concerns arranging or facilitating the travel of another with a view to exploiting them.

Obsidian Healthcare takes its responsibility for supplying workers extremely seriously and are aware of the risks that our business activities attract. It is the mandate of Obsidian Healthcare to conduct business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure modern slavery and human trafficking is not only prevented but fished out and dealt with according to the provision of the law.

Structure & Business.

Obsidian Healthcare is a healthcare recruitment agency, placing temporary care workers into Private Healthcare sectors within the UK.

Policy Statement.

Obsidian Healthcare is committed to working in a transparent, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

Obsidian Healthcare will constantly uphold all laws relating to modern slavery and in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Modern Slavery Act 2015, in regards to our conduct both at home and abroad.

Due Diligence.

Obsidian Healthcare ensure strict and thorough compliance checks are carried out for all candidates that we supply. During the registration and vetting process, the identity of each candidate and their right to work are fully vetted in line with the Home Office guidance and NHS employer’s checking standards. All our staff and candidates have access to dedicated whistle blowing channels.

Employee Responsibilities.

As an employee of Obsidian Healthcare, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-slavery information you are given.

All employees and those under our control are equally responsible for the prevention, detection, and reporting of slavery and other forms of modern slavery. They are required to avoid any activities that could lead to, or imply, a breach of this anti-slavery policy.

If you have reason to believe or suspect that an instance of modern slavery has occurred or will occur in the future that breaches this policy, you must notify your line manager.

If any employee breaches this policy, they will not only face disciplinary action, dismissal for gross misconduct but also report it to legal authorities. Obsidian Healthcare has the right to terminate a contractual relationship with an employee if they breach this anti-slavery policy.

What happens if I need to raise a concern?

This section of the policy covers 3 areas:

How to raise a concern.
What to do if you are a victim of modern slavery.
Protection.

How to raise a concern.

If you suspect that there is any form of modern slavery taking occurring in relation to Obsidian Healthcare, you must raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour falls within the definition of modern slavery (as provided above), you should speak to your line manager or the Managing Director.

What to do if you are a victim of Modern slavery.

You must tell your line manager as soon as possible if you experience or suspect another within or in affiliation to Obsidian Healthcare or it’s connected suppliers. All concerns reported to management will be dealt with in accordance to the UK Government guidance. Should you suspect a patient/service user you care for whilst working is a victim of modern slavery, you must raise your concern in line with the Trust policy. Should you be worried to report this, please ensure you notify the Clinical Nurse Manager at Obsidian Healthcare who will notify the client.

Protection.

If you experience or you report a concern relating to potential act(s) of modern slavery, Obsidian Healthcare understands that you may feel worried about potential repercussions. Obsidian Healthcare will support anyone who raises concerns in good faith under this policy; even if investigation finds that they were mistaken.

Obsidian Healthcare will ensure that no one suffers any detrimental treatment as a result of reporting a concern relating to potential act(s) of modern slavery.

Detrimental treatment refers to dismissal, disciplinary action, threats, or unfavourable treatment in relation to the concern the individual raised.

If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or reporting, you should inform your line manager or the Managing director immediately.

Training & Communication.

Obsidian Healthcare will provide training on this policy as part of the induction process for all new employees and candidates.

Obsidian Healthcare’s anti-slavery policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at as needed at the outset of business relations, and as appropriate thereafter.

Obsidian Healthcare will provide relevant anti-slavery training and support to its employees and candidates they may require with regards to human trafficking, forced labour, servitude and slavery.

Record Keeping.

Obsidian Healthcare will keep detailed and accurate records of employees and candidates (in line with the Data Protection policy and procedure) and will have appropriate internal controls in place to support this policy.

Monitoring & Reviewing.

Obsidian Healthcare’s Managing director is responsible for monitoring the effectiveness of this policy and will review the implementation of it on an annual basis. They will assess its suitability, adequacy, and effectiveness.

Internal control systems and procedures designed to prevent all forms of modern slavery are subject to regular checks to ensure that they are effective in practice.

Where there is a need for improvement, we will ensure they are implemented as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the line manager.

This policy does not form part of an employee’s contract of employment and Obsidian Healthcare may amend it at any time so to improve its effectiveness at combatting modern slavery.