Modern Slavery Statement

Introduction

This statement is made pursuant to obligation under section 54(1) of Modern Slavery Act 2015 (Act), for financial year 2023. We understand modern slavery and human trafficking as defined in the Act, the UN Universal Declaration of Human Rights and the conventions of the International Labour Organisations (ILO), particularly relating to forced or compulsory labour. With Modern Slavery still happening across the country and affecting an estimated 13000 victims of trafficking, The Modern Slavery Act was designed to seek out and eliminate such horrendous crimes of human trafficking, slavery and compulsory labour. Our aim is to address the requirements of the Modern Slavery Act (2015), despite our annual turnover not exceeding £36 million. We are committed to proactively combating modern slavery and human trafficking within our operations and supply chain, demonstrating our dedication to ethical practices and social responsibility beyond statutory obligations.

Modern Slavery Statement

ClinicalPro ltd recognises that slavery and human trafficking is a crime and a violation of fundamental human rights. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

The aim of the Company is to identify our responsibility by alerting staff to the risks, however small, in our business and in the wider supply chain. Staff are expected and encouraged to report concerns to management, where they are expected to act upon them. Company activities are varied through multiple disciplined areas such as recruitment of Medical Staff, Nursing – nurses and healthcare assistants, Allied Health Professionals, Non-clinical and Non-medical staff to NHS. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

About ClinicalPro

ClinicalPro Group is a leading global healthcare recruitment agency specializing in the recruitment of all healthcare professionals. Established 18 years ago, we have come a long way from starting as a Locum Doctors agency to further expanding into Locum Nursing and Overseas recruitment agencies helping global talent connect with the UK healthcare sector. Our mission is to place the right candidate in the right employment for their skills, experience and requirements in the shortest time possible.

Our people are industry experts, providing staffing solutions for the NHS and private healthcare providers, including nurses, doctors, Allied Health Professionals (AHP) and Health Science Staff (HSS).

We strive to offer a seamless service to our clients and continue to challenge ourselves and our services to ensure we are one step ahead.

We are dedicated to treating every individual with the utmost respect while promoting equality and diversity for all workers, employees, and applicants. The Directors of ClinicalPro uphold a zero-tolerance policy towards modern slavery, human trafficking, bribery, corruption, and any indirect association with these criminal activities. ClinicalPro  is committed to engaging only with partners and supply chains that share these values,ensuring transparency and accountability throughout. By collaborating, we move closer to eliminating egregious crimes such as human trafficking and modern slavery.

Our People

• We are dedicated to fair working practices.
• We ensure that all our staff receive payments that meet or exceed the National Minimum Wage requirements.
• As an equal opportunities employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our staff.
• As a recruitment agency, we are governed by The Recruitment & Employment Confederation (REC).
• Full details of our recruitment policies are available upon request.
• Our recruitment and people management processes are designed to ensure that all prospective employees have the right to work in the UK and to safeguard employees from any abuse or discrimination.
• We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Our Policies and Conduct

As a leading recruiter, ClinicalPro is dedicated to ensuring that neither our business nor our supply chain tolerates modern slavery, forced labor, or human trafficking in any form. We thoroughly vet all our candidates according to recruitment guidelines for right-to-work documentation and collaborate closely with the Home Office when verification is needed.

ClinicalPro is committed to maintaining and upholding compliance standards by regularly conducting internal auditing and undergoing audits by affiliated framework agreements and the NHS.

The following policies are available to all staff through our internal policy resource :

• Code of Conduct
• Recruitment and selection policy
• Whistleblowing policy
• Equality policy
• Safeguarding policy
• Conflict of Interest policy
• Anti- Bribery Policy
• Ethical practice policy

Due Diligence and Risk Assessment

As a major multi Framework agency, our recruitment processes follows government procurement standards including but not limited to:

• Crown Commercial Service
• Health Trust Europe
• Shared Business Service
• London Procurement Partnership
• Care Inspectorate (Scotland)
• NHS Employers

• We ensure that More stringent vetting and investigation of our supply chain (contractors, sub-contractors, policies, contracts etc.). The company will not knowingly support or deal with any business involved in slavery or human trafficking.
• We adhere to the criteria set out in all Framework Agreements and Call-off Contracts held, and all Tier structures and SLAs that are put in place.
• We are also members of the Recruitment and Employment Confederation (REC) and adhere to their Code of Professional Practice. This commitment ensures our practices not only meet basic statutory compliance but also align with higher ethical standards.
• To assess the risk of modern slavery, we use all the appropriate processes with our supply chain. For instance, continuous audits and review of payroll to ascertain that all employees are paid in accordance with minimum wage standards and right to work guidelines.
• We encourage the reporting of concerns and a policy to protect whistle blowers. We have zero tolerance to slavery and human trafficking. We expect our clients and all those in our supply chain and contractors comply with our values.
• When engaging with our supply chain, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing. 

• We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks. 

• Ensuring candidates have the correct right to work status and documents. Appropriate clearance is obtained (via DBS, PVG and Access NI respectively).
• Policies and procedures in place, all staff are trained and informed of policies and procedures with a signoff sheet.

We have not identified any areas of the business that we consider to be high risk, but continue to monitor and assess all aspects of our policies and processes

Breach of policy:

• Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
• We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Our Training

All of our staff receive training and support that is appropriate to their role.  In particular:

Our Risk Management Director received a detailed training in identifying and resolving concerns around modern slavery and human trafficking.

Our HR Manager 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. We provide refresher training mYLOC

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 employees, the public, police , local Authority or law enforcement agencies to indicate that modern slavery practices have been identified.

Statement Approval

This statement, as shown, was approved by the Risk Management Director on 27^th September 2023 and duly authorized by Raj Nathan, CEO.

Signed and Dated

Name: Kirty Salaria
Position: Risk Management Director
Date: 27/09/2023