Modern Slavery and Human Trafficking Act 2017 Statement 

1.     Introduction

At Integrated Care 24 Limited (IC24) we are committed to ensuring that no modern slavery or human trafficking takes place in any part of our business or our Supply chain. This statement sets out actions taken by IC24 to understand all potential modern slavery and human trafficking risks and to implement effective systems and controls.

Section 54 of the Modern Slavery Act 2015 requires us to set out the steps that we have taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business.


2.     Organisational Structure

IC24 provides a comprehensive range of urgent primary care services for approximately six million people across the following locations:

  • Kent (excluding Medway)
  • Brighton & Hove
  • East Sussex
  • West Sussex
  • East Surrey
  • Essex
  • Great Yarmouth & Waveney
  • Northamptonshire
  • Norfolk & Wisbech

Our annual turnover is over £64 million. We deliver four 111 services from our three care co-ordinations services and OOH care is provided from 50 bases across the localities. In addition IC24 provide:

  • Health and Justice Healthcare in Sheppey Prison Group
  • GP Led Walk in centres in Hastings & Eastbourne
  • District Nurse overnight service
  • Two 100 hour pharmacies

Our workforce comprises of over 1500 staff including both clinical and non-clinical staff.


3.     Our Policy on Slavery and Human Trafficking

IC24 have internal policies and procedures in place that assess supplier risk in relation to the potential for modern slavery or human trafficking. The top 80% of suppliers nationally, affirm their own compliance with the modern slavery and human trafficking act within their own organisation, sub-contracting arrangements and supply chain.

All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking with the Finance Department taking responsibility for overall compliance.


4.     Due Diligence

To identify and mitigate the risks of modern slavery and human trafficking in our own business and our supply chain we:

  • Purchase a significant number of products through NHS Supply Chain, whose ‘Supplier Code of Conduct’ includes a provision around forced labour.
  • Where possible, build long standing relationships with suppliers.
  • IC24 will request all suppliers to comply with the provisions of the UK Modern Slavery Act (2015), through agreement of our ‘Supplier Code of Conduct’, purchase orders and tender specifications. All of which will set out our commitment to ensuring no modern slavery or human trafficking related to our business.
  • IC24 will write bi-annually to our top suppliers by spend requesting them to affirm their compliance with the legislation. The resultant Supplier Policies shall be logged, scanned and recorded.
  • No new suppliers will be approved without confirming their compliance with the legislation.
  • IC24 will ask for evidence of Policy existing as part of all formal tender processes.
  • IC24 undertakes an annual audit on non-pay expenditure as part of their audit plan. The audit includes a statutory compliance element including the modern slavery and human trafficking act requirements.
  • IC24 will review compliance with our policy requirements as part of the Annual Accounts process.


5.     Training

We have achieved some development of colleagues on this subject during the 2016 and 2017 period with clinical and management teams having exposure to modern slavery and human trafficking development as part of wider development programmes.

Modern Slavery will be part of our essential learning programme when we implement our new learning management system in July 2018.

IC24 considers the principal risks related to slavery and human trafficking and identifies them as:

  • Reputational
  • Lack of assurances from suppliers
  • Lack of anti–slavery clauses in contracts
  • Training staff to maintain our position around anti-slavery and human trafficking


6.     Aim

The aim of this statement is to demonstrate that IC24 follows good practice and all reasonable steps are taken to prevent slavery and human trafficking.


7.       Board of Directors’Approval

The Board of Directors has considered and approved this statement and will continue to support the requirements of the legislation.


Judy Oliver                                                                            Yvonne Taylor

Chair                                                                                     Chief Executive