Modern Slavery Statement

Introduction

This statement sets out ICS's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2019 to 31 March 2020.

As part of the healthcare sector and recruitment industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

 

Organisational structure and supply chains

This statement covers the activities of ICS:

With over 30 years recruitment experience, ICS has built an excellent reputation as a market leader for recruiting and supplying highly skilled specialist candidates throughout the UK and overseas. ICS grow and diversify the markets we serve by recruiting and retaining the best people, empowering them with innovative technology solutions. Our aim is to be the first-choice partner for health, life sciences and social care professionals and providers, across the globe. Our solutions are delivered through three segments; specialised staffing, workforce management solutions, and health and social care services.

 

We currently operate in the following 10 countries:

United Kingdom, Ireland, USA, Germany, Sweden, Switzerland, Singapore, China, Japan, and Australia.

 

We are committed to improving our practices to combat slavery and human trafficking. We recognise that slavery and human trafficking is a real, yet hidden issue in our society. We will not tolerate slavery and human trafficking in our business or supply chain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that any form of slavery is not taking place in our own business or supply chains.  Whilst we assess the risk of modern slavery as low in our supply chain, we have taken appropriate steps to ensure our procedures are appropriate by:

 

  • Ensuring robust recruitment procedures which include immigration checks
  • Ensuring employees and Temporary Workers have the correct right to work status and documents
  • Confirming that appropriate clearing is obtained (e.g. DBS, PVG, Access NI)
  • Ensuring employees and Temporary Workers are appropriately trained
  • Strong policies and procedures for the business overall are in place

 

Our business and livelihood depend upon our customers. Every employee is responsible for ensuring that any contact with our customers and the public at large reflects professionalism, efficiency and honesty. We constantly strive to provide a ‘Best Value’ high quality service:

 

  • We shall uphold the values of honesty, partnership and fairness in our relationships with stakeholders
  • We shall ensure a high level of business performance while minimising and effectively managing risk
  • We shall strive to provide continuous improvement in terms of service quality and cost
  • We will register and resolve customer complaints in accordance with our standards of service.
  • We will deal fairly with Temporary Workers and suppliers in our supply chain.
  • We will not create barriers to the use of small and medium-sized enterprises who are qualified to provide goods or services, and we will encourage innovation in our supply chains to increase the value or quality of supply.
  • We will be fair and reasonable in our payment practices.

 

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

 

Policies: The Group Clinical Director and Chief People Officer are responsible for the policy management, control and administration of the policy development process which includes: maintaining a central register of all policies, ensuring policies are reviewed in a timely manner, ensuring consistency through the policy development process, archiving superseded policies onto ICS Pages and removing superseded policies.

Investigations/due diligence: ICS adopts a transparent approach to the recruitment and placement of our candidates and employees, and fully complies with the Duty of Candour principles, and the Modern Slavery Act 2015. ICS has robust contracts and/or service level agreements with all supply chains which promote transparency between both parties. Any incidents of Modern Slavery and/or Human Trafficking are documented, investigated (if appropriate) and referred appropriately to the regulatory bodies in accordance with the ICS Incidents Policy/Procedure and in line with the Modern Slavery Act 2015. 

Whistleblowing:  ICS has an independent whistleblowing hotline that employees can access if they suspect modern slavery is taking place.

Training: All ICS employees complete a Modern Slavery training module at the start of their employment.  Refresher training will be applicable for all ICS employees regularly thereafter.

 

Relevant policies

Modern slavery, Human Trafficking and other forms of exploitation are included in the ICS Safeguarding Adults and ICS Safeguarding Vulnerable Children Policies.  These policies include warning signs and reporting/escalation processes. Other policies and procedures that further support the identification and management of Modern Slavery and Human Trafficking are:

 

  • ICS Incidents Policy
  • ICS Complaints Policy
  • ICS Equality, Diversity and Human Rights Policy
  • ICS Recruitment Policy and Procedures
  • ICS Corporate Responsibility Policy
  • ICS Whistleblowing Policy
  • ICS Safeguarding Policies for Adults and Children

 

Performance indicators

We have reviewed our key performance indicators (KPIs). As a result, we are:

 

  • Continuing to review our policies and procedures to ensure that any form of slavery is not happening in our own business or supply chains
  • Ensuring robust recruitment procedures which include immigration checks are in place
  • Ensuring employees and Temporary Workers have the correct right to work status and documents
  • Confirming that appropriate clearing is obtained (DBS, PVG, Access NI)
  • Ensuring employees and Temporary Workers are appropriately trained
  • Requiring all ICS employees to complete modern slavery training when they commence employment with ICS, and regularly thereafter

 

Training

All ICS employees complete a Modern Slavery training module at the start of their employment.  Refresher training will be applicable for all ICS employees regularly thereafter.

 

Awareness-raising Programme

As well as training staff, we will raise awareness of modern slavery issues by circulating a series of emails that will explain to staff:

  • The basic principles of the Modern Slavery Act 2015
  • What external help is available, for example through the Modern Slavery Helpline, and other resourceful websites
 
Mike Barnard,
Chief Executive Officer