Modern Slavery and Human Trafficking Statement 2023-24

 

Introduction

Modern slavery is a serious and often hidden crime, and the impact can be devastating for the victims.  Modern slavery can be broadly grouped into five categories but is not limited to:

  • sexual exploitation: this includes sexual abuse, forced prostitution and the abuse of children for the production of child abuse images, videos or live streaming
  • domestic servitude: this involves victims being forced to work in usually private households, performing domestic chores and childcare duties
  • labour exploitation: this can happen in various industries, including construction, manufacturing, laying driveways, hospitality, food packaging, agriculture, maritime and retail businesses that reply on cash payments (for example nail bars and car washes)
  • debt bonded labour: this is a form of forced labour when a person is forced to work to pay off a debt. They are tricked into working for little or no pay, with no control over their debt. This is thought to be the most widespread form of slavery today
  • criminal exploitation: this can be understood as the exploitation of a person to commit a crime, such as pick-pocketing, shoplifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker
  • other forms of exploitation include organ removal, forced begging fraud, marriage, and illegal adoption

This statement comprises the slavery and human trafficking statement of The Hurley Group (the organisation) for the financial year ending 31 March 2024 in accordance with Section 54, Part 6 of the Modern Slavery Act 2015.  The organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its corporate activities.

This annual statement sets out the Hurley Group’s actions to understand all potential modern slavery risks related to our activities and to put in place steps to eliminate acts of modern slavery and human trafficking within our business and in our supply chains, sub-contractors and partners.

The Partners, executive team and all employees are committed to ensuring that there is no modern slavery or human trafficking in any part of our business activity and in so far as is possible to holding our suppliers to account to do likewise.
The publication of this annual statement is part of that commitment and highlights our activities to address this.

1. Organisational structure and supply chains

Hurley Group is an NHS Partnership led by practicing GPs, providing patient-centred care in London and surrounding area.  

We:

  • deliver GP services to approximately 120,000 registered patients across eleven sites.
  • run two urgent care centres.  The urgent care centres provide urgent care to patients who have a minor illness or injury that requires immediate treatment.  The urgent care centres are open seven days a week, one service is open 24 hours a day.
  • run Practitioner Health which is a free, confidential NHS primary care mental health and addiction service with expertise in treating health and care professionals.
  • run the Primary Care Gambling Service which provides integrated support services to anyone experiencing gambling harms across South London.  The service is supported by a multidisciplinary team of mental health nurses, GPs, treatment practitioners and therapists.

2. Policies in relation to modern slavery and human trafficking

We have a number of policies and procedures in place that aim to ensure modern slavery does not occur in our organisation:

  • Robust recruitment policy and process

Our recruitment policy and supporting processes are compliant with UK employment legislation, the process includes several pre-employment checks, for example 'right to work' document checks, referencing and understanding any employment gaps. DBS checks are undertaken for relevant posts:

  • Safeguarding vulnerable adults and children

All staff are required to complete mandatory training where awareness of modern slavery addressed:

  • Reporting knowledge or suspicion of modern slavery 

Our staff are supported to report any concerns they have.  Our whistleblowing procedure ensures that staff can raise any concerns confidentially.

3. Due diligence process

Our organisation aims to be as effective as possible in ensuring that modern slavery and human trafficking is not taking place in any part of our business or supply chains by:

  • Signing up to the multi-agency policy and procedures for the protection of adults with care and support needs
  • Effective interagency working with local authorities, the police and third sector organisations which includes appropriate arrangements for preventing and responding to modern slavery and human trafficking
  • Undertaking robust pre-employment checks 
  • Expecting providers in our supply chains to have suitable anti-slavery and human trafficking policies and processes in place

4. Risk assessment and management

  • All staff received guidance explaining what modern slavery is, how to identify it, and how to log concerns.
  • All recruited permanent and temporary staff are subject to identification and background checking.
  • We pay the London living wage.

5. Effectiveness

We are committed to the following actions to further improve our effectiveness for the coming year:

  • We will review our safeguarding policies to update them regarding modern slavery and human trafficking.

6. Training

Evidence has shown that when victims present in healthcare services, healthcare professionals are not always equipped to know how best to support them.  

All staff are required to complete a number of compulsory training modules, with awareness of modern slavery addressed through the safeguarding children and adults level 2 training modules.  

Additional safeguarding training is required to be undertaken by specific staff groups.

7. Finding help

If you or someone you know is being or has been exploited or you are unsure if someone is in need of help, assistance and advice is available via the following.

This statement will be published on the Hurley Group website and reviewed on an annual basis.

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes The Hurley Group’s modern slavery and human trafficking statement for 2023-24.

Signed on behalf of the Partners: Ben Shankland, Partner