Modern Slavery Statement

Introduction

Lakeside Healthcare is committed to preventing modern slavery and human trafficking in our operations and supply chains. As a provider of primary care services within the NHS, we recognise our responsibility to ensure ethical practices in all aspects of our work. This statement outlines the steps we have taken to identify, mitigate, and address risks related to modern slavery, in compliance with the Modern Slavery Act 2015.

Our Business and Supply Chains

Lakeside Healthcare operates within the NHS primary care sector, delivering essential healthcare services to patients. We work with a range of suppliers, including medical equipment providers, pharmaceutical companies, facility management services, and staffing agencies. We recognise that some areas of procurement, such as temporary staffing and medical supply chains, may pose risks for modern slavery, and we are committed to ensuring ethical labour standards throughout our operations.

Assurance and our Approach to Slavery and Human Trafficking

We are dedicated to preventing modern slavery and human trafficking within our supply chains and across all aspects of our business. Our Anti-Slavery policy underscores our commitment to conducting business ethically and with integrity in all our relationships. We strive to implement and maintain effective systems and controls to ensure that these practices do not occur in our operations or those of our suppliers. 
This statement is published on our partnership website and available to staff via our compliance platform Radar

Processes

As part of our initiative to identify risk and mitigate against such risks, our Management Board takes responsibility through our Executive Board and management teams for ensuring our practices identify pertinent risks.

We have established systems and approaches across our organisation and supply chains, which include:

• A thorough recruitment process for staff that includes identity verification, DBS checks, qualification and reference verifications, as well as checks to confirm that recruits are legally entitled to work in the UK.
• A rigorous due diligence process for staff agencies and locums we may contract with, ensuring they meet our recruitment standards.
• A comprehensive framework for utilizing volunteers, who are issued honorary contracts following appropriate clearance checks, including verification of their right to work in the UK and a DBS check. All volunteers undergo the same onboarding, induction, and site orientation as paid employees. Their support is provided on an ad-hoc basis, with hours monitored in accordance with the working time directive to ensure adequate rest breaks.
• The implementation of strict workplace conduct codes, referencing these within our contracting documentation for all staff and aligning with the NHS code of conduct in relation to expected standards for management.
• Mandatory training for all staff to enhance awareness and clarify responsibilities concerning the Act, particularly towards our patients.
• Supplier due diligence assessments to ensure compliance with ethical standards.
• A commitment to uphold our values by adhering to responsible sourcing principles. All staff members share the responsibility for preventing unethical practices within our operations.
• Active engagement with our stakeholders and suppliers to address the risks of modern slavery in our operations and supply chains. In instances where individuals or organizations acting on our behalf are found to have violated these standards, we will take appropriate actions, which may include remediation or termination of relationships, depending on the circumstances.
• A collective responsibility among all employees and contractors to prevent, detect, and report any occurrences or indications of modern slavery within our organization or supply chains. Employees are expected to refrain from engaging in or failing to report activities that could represent a breach of these standards.
• Collaboration with NHS bodies and regulatory authorities to foster transparency within our supply chains.

Policies on Modern Slavery

Lakeside Healthcare have a range of Policies to guide staff on routes for whistleblowing, grievance, disciplinary and bullying and harassment, provide them with assurance on our management role and providing support with relevant workforce to support such policies, such as centralised Human Resources experts, centralised Safeguarding experts, Mental Health First Aiders and Freedom to Speak Guardian.

Monitoring and Measuring Effectiveness

We continuously review our policies and processes to ensure their effectiveness. Key performance indicators (KPIs) include:

• Reports received through our whistleblowing mechanism.
• Corrective actions taken in response to identified risks.

Future Commitments

We are committed to further strengthening our efforts against modern slavery by:

Implementing a range of policies to prevent modern slavery, including:

• A Code of Conduct outlining our commitment to ethical business and employment practices.
• A Supplier Code of Ethics, requiring our suppliers to adhere to NHS labour standards and anti-slavery policies.
• A Procurement Policy ensuring due diligence in supplier selection and contract management.

Additional management training and wellbeing support awareness has been undertaken, and which will form part of mandatory management training to ensure all employees with line management responsibility are consistent in their approach to staff recruitment, employment rights and awareness and support to ensure the correct management of employee welfare

Documenting supplier compliance checks conducted.