Modern Slavery Policy
Introduction
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This statement is made pursuant to section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015 and constitutes Osborne & Allan’s modern slavery and human trafficking statement for the year 2023/24. It sets forth the steps taken by us, to prevent modern slavery and human trafficking in its business and supply chain. This policy applies to all our employees, temporary employees, contractors, or any individual acting on or behalf of us.
Modern slavery is a crime and a grave infringement on the core principles of human rights. It takes various forms, including slavery, servitude, compulsory labour, and the despicable act of human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Osborne & Allan is committed to a zero-tolerance approach to modern slavery and is committed to conducting its business with ethics and integrity. We diligently establish and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.
Osborne & Allan fully supports the government’s objective to eradicate modern slavery and human trafficking, focusing on ethical and labor standards abuses in its supply chains and business activities, and supporting victims. As a recruitment industry, Osborne & Allan is aware of potential risks related to human rights violations in areas like nursing, aged care provision, and healthcare equipment manufacturing. We are committed to monitoring these risks and mitigating them in our business and supply chain.
Organisational Structure
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Osborne & Allan is an Healthcare Recruitment Agency registered in the United Kingdom. Our sphere of influence in the healthcare sector is continuously growing as we are extending our staffing services internationally, including privately and publicly owned hospitals, and, in some cases, to various other private and public organisations and businesses involved in the administration or provision of health services. Our candidates are fully supported throughout the entire recruitment process, from the day they enroll with us till the day they begin their work at their employer’s facility. Our office is based in the UK with branches in India, UAE and South Africa.
Steps taken to date include:
Due diligence process
We promote a workplace environment that is fair, open, and respectful, and one that protects the rights and dignity of all employees. We operate people practices, contracts of employment and collective agreements that are lawful and aligned to our Code and values.
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We confirm the identities of all new employees, temporary workers and contractors and their right to work in the United Kingdom, and pay all our employees above the National Living Wage
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Our Respect at Work, Grievance and Voicing your Concerns for Staff policies additionally give a platform for our employees to raise concerns about poor working practices.
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We use social media to raise awareness and invest in training to ensure front line staff are aware of and able to respond to incidents of modern slavery.
Communication And Awareness of Policy
Training will be made available as needed, both on this policy and on the potentialthreats our business may encounter concerning modern slavery within its supplychain. Our unwavering commitment to zero tolerance for modern slavery will beclearlycommunicatedtoallemployees,suppliers,andcontractorsatthecommencement of our business relationship with them, and it should be reinforced asappropriateover time.
Whistleblowing
Our whistleblowing policy sets out our commitment to ensure people are free to question things and raise anything they are concerned about and specifically modern slavery and human trafficking. We encourage people to speak up by raising matters with their respective Office Managers at the respective location or emailing their concerns to hello@osborneallan.co.uk
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
Compliance With the Policy
To implement this policy effectively and to ensure transparency in our business, we expect a high standard and cooperation from our employees. They have a duty to see whether this policy is rightly implemented.
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It is the duty of every individual operating within our organization or under our authority to actively participate in the prevention, identification, and reporting of modern slavery in any aspect of our business or supply chain. You are expected to refrain from engaging in any actions that could potentially result in or imply a violation of this policy.
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You must notify the concerned office manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
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If you have uncertainties regarding whether a specific action, the treatment of workers in a broader sense, or the working conditions at any level of our supply chain might involve any of the different manifestations of modern slavery, raise them with your office manager.
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The Office Manager holds the central and daily responsibility for executing and overseeing the utilization and efficiency of the policy. This includes addressing any inquiries related to the policy and conducting internal audits of control systems and procedures to verify their effectiveness in combating modern slavery.
Procurement and our supply chain
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Our current due diligence process includes a modern slavery assessment.
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When procuring goods and services, we additionally apply specific Terms and Conditions that require suppliers to comply with relevant legislation.
Review of effectiveness
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We intend to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in our supply chains.
We will assess the efficiency of our actions to ensure there is no slavery or human trafficking in our business or supply chain if:
No reports are submitted by our employees, members of the public, or law enforcement agencies indicating the presence of modern slavery practices.
In 2023/24, our anti-slavery program will also:
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continue to support all staff to understand and respond to modern slavery and human trafficking, and the impact that each, and every individual working in the healthcare sector can have in keeping present and potential future victims of modern slavery and human trafficking safe.
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Ensure that staffs have access to training on how to identify those who are victims of modern slavery and human trafficking. This training will include the latest information and will help staff develop the skills to support individuals who come into contact with health services.
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review our safeguarding policies and training programs to ensure that Modern Slavery and human trafficking reflect potential requirements in pending reforms relating to the pre-criminal needs of people involved in human trafficking and modern slavery.
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Undertake a risk assessment on transparency in supply chain including an overview of products, services and suppliers procured.