This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) and covers the calendar year 2020. It sets out the steps taken, by Spire Healthcare Group plc and other relevant group companies1 to prevent modern slavery and human trafficking in its business and supply chains.
Spire Healthcare is a leading independent hospital group in the United Kingdom. We deliver high standards of care to our insured, self-pay and NHS patients across 39 hospitals and eight clinics. We are a public company quoted on the London Stock Exchange (SPI: LSE). Our registered office is 3 Dorset Rise, London, EC4Y 8EN and our financial year ends 31 December. You can read more about our business in our latest Annual Report.
Spire Healthcare’s purpose is to ‘make a positive difference to our patients’ lives through outstanding personalised care’. This purpose underpins everything we do and is complemented by one of our values, ‘Doing the right thing’, in demonstrating our commitment to act ethically and with integrity in all our relationships.
In 2018 a cross-department ‘Working Group’ was established to oversee modern slavery risk in the business. The Group includes senior representatives from Legal, HR, Procurement, Operations, Audit and Risk and also the Executive Committee.
As a national, multi-site organisation, we buy a wide-range of goods and services, from surgical equipment and medicines, through to clothing and waste disposal. Some of these products and services are used in the provision of healthcare to patients, such as joint prostheses, whilst others will be used in the business, such as office supplies. We engage thousands of suppliers, making the totality of our end-to-end supply chains extensive and complex, however 80% of group spend is with c.270 vendors. At tier-one level 99% of our suppliers are UK-based businesses, but as is often the case we have limited visibility beyond that level and acknowledge that it will be in the remote parts of long global supply chains where there will be more risk.
1Spire Healthcare Group plc and Spire Healthcare Limited both of which fall within the scope of the Act
In 2020 we reviewed and risk-assessed the modern slavery statements for all our suppliers who collectively represent 50% of the business’s total spend. Overall we were pleased with the improved quality of statements, having conducted a similar exercise in 2017. We also embedded (with effect from 31 March 2020) a new modern slavery due diligence process for all material new suppliers (those with an annual spend of £1m+). If any such supplier is deemed medium or high risk then they would be further risk assessed through a detailed modern slavery questionnaire.
To date we have not had an issue with a supplier’s modern slavery compliance position. If such an issue were to arise then, on a case-by-case basis, we would first look to work with any supplier, where there is realistic prospect of remedy/reform, but equally we would not hesitate to engage alternative suppliers or immediately cease dealings with that supplier if necessary.
The details of our 2021 plans on supplier due diligence are set out in the next section and we will report on the outcome of these actions in our next statement.
We recognise that, whilst we are a UK-based business, modern slavery is a complex, global issue which does affect the healthcare sector. The two main areas of focus in our business are at front-line level, in safeguarding patients (and anyone else who comes through our facilities), and in our supply chain.
In terms of our business operations, we believe practitioners and our staff are uniquely placed to identify and deal with modern slavery through the training and protections in place to protect patients. The safeguarding system trains those practitioners and other colleagues (clinical and non-clinical) to recognise and report signs of abuse (including modern slavery which now has a specific classification). We believe the rigour of this system mitigates the risk of modern slavery from either going undetected or being inadequately dealt with at front-line level. The front-line risk is further controlled by the support, training and infrastructure in place for all colleagues to be able to raise concerns, through our network of local ‘Freedom to Speak up Guardians’, central concerns email or, if necessary, via a confidential external whistleblowing helpline.
One area which we acknowledge the wider modern slavery debate flags as an area of potential risk is the contracting of low/un-skilled labour. The vast majority of people who run our business are employed and must satisfy all necessary employment checks for their role. We also ensure we comply with the current National Minimum Wage and Living Wage. Whilst we believe there are a very limited number of non-employed people who undertake such category of labour for our business (e.g. contract cleaning or gardening) we will undertake a full review, and any necessary further due diligence, in 2021 to check for any modern slavery risk and report on our findings in our next statement.
The most significant risk of modern slavery within our business is in our group supply chain. As set out above in ‘Due Diligence Processes’ we are pleased that we completed our plan to review our key suppliers’ latest statements and further develop our due diligence process to build on the progress we made in 2019. Following the enhanced due diligence of certain higher-risk suppliers, which we undertook in 2019, we have continued to canvas trade press, main stream media and other investigative reports to gain further insight of risks in the supply of goods used in healthcare, specifically: low cost medical consumables, surgical instruments and garments (e.g. surgical gowns, aprons and uniforms) manufactured in developing countries. We have considered these specific product risks more acutely in the context of the impact of COVID-19. We are aware that the pandemic has worsened the landscape for modern slavery by heightening risks for those already exploited; increasing the risks of exploitation; and disrupting efforts to combat modern slavery. These factors combined with the massive global demand for PPE makes this product category a higher risk area and one where we will focus our efforts in 2021.
During the pandemic period we sourced a large part of our PPE through NHS Supply Chain via Clipper Logistics plc (pursuant to our arrangements to support the NHS). We are aware that the division of NHS Supply Chain, which supplied us with that PPE, reports on how it addresses modern slavery under the Act, so we have taken assurance from this fact (but otherwise have been wholly reliant on their due diligence processes being robust). Furthermore we received a supply of COVID-19 lateral flow test kits through NHS Test and Trace and again we were wholly reliant on their due diligence processes. During 2021, as we expect to transition back to our own supply chain, we will be engaging with our major suppliers of PPE products (specifically medical gloves and face masks) to go beyond those due diligence checks already done to understand more about the internal controls of these suppliers and how they engage with their own supply chains. We will report on the outcome of this exercise in our 2021 statement.
As well as engaging directly with those suppliers we will also assess the value of a number of third party risk management tools/databases which assist with the difficult process of understanding the risk in a complex supply chain to see if any can help make the output of this and other future due diligence processes as rigorous and useful as possible.
We have considered the utility of KPIs, or other quantitative metrics, to measure our progress and decided that in this context they are not helpful or meaningful. Instead we have chosen to adopt a qualitative approach by assessing our business for areas where modern slavery has the potential to have the most impact and then focus on these areas to identify, undertake and continuously build on appropriate actions which will have the biggest impact on reducing and ultimately eliminating modern slavery from touching our business.
A number of key polices relating to the risk of modern slavery touching our business were updated in 2019 (including specific updates for modern slavery). No relevant policies were due for update in 2020. These key policies comprise the Group Purchasing Policy, Safeguarding Adults at Risk and the Procedure for Safeguarding Children & Young People. Our Whistleblowing Policy, which sets out our commitment to ensuring colleagues are empowered to raise concerns, will shortly be replaced by a broader Raising Concerns Policy.
Training and raising awareness is absolutely fundamental to ensure all our colleagues understand the importance of this issue, and particularly at front-line level, know the practical signs of modern slavery and how to respond. After widespread training was undertaken in 2019, our non-core training programme was affected by the pandemic in 2020. Early in the year, we did deliver training on modern slavery to a number of hospital leadership teams and we will be restarting this programme in 2021. Our Group core mandatory training programme was completed and comprises: i) e-learning module for Safeguarding Adults at Risk Combined Level 1 & 2 (which covers modern slavery as a category of abuse and is mandatory for all employed staff); ii) Level 3 Safeguarding Adults module (which also covers modern slavery as a category of abuse and is mandatory for all registered healthcare staff); and iii) Level 4 Safeguarding Officer Training (Adults and Children) (which covers relevant local authorities’ modern slavery safeguarding protocols and the duty to notify). This is mandatory for all Hospital Directors and local Safeguarding Leads. This programme of training ensures that it is those who undertake the higher levels of training who will be more likely to come into direct contact with incidents of modern slavery. Finally following the successful modern slavery training to all registered managers in 2019, we have made modern slavery a standing item on the agenda of all future registered managers’ training days.
On National Anti-Slavery Day in October we raised awareness of modern slavery risk, across the Group on our employee App, Ryalto. In 2021, we will continue to develop and roll-out our training programme to raise awareness on modern slavery risks and plan to launch our largest Group modern slavery awareness campaign.
We abhor the practice of modern slavery – it cuts right across Spire’s Purpose and Values. We are committed to continuously developing and strengthening our approach, each year, to make meaningful progress towards eradicating this crime.
This statement was approved by the Board of Directors of Spire Healthcare Group plc on 7 April 2021.
Chief Executive Officer
On behalf of the Board of Directors of Spire Healthcare Group plc
7 April 2021