Cleveland Clinic London Ltd ("CCL") is a subsidiary of The Cleveland Clinic Foundation, a US non-profit academic medical centre and leader in research, education and health information. It continues to be a priority for CCL to ensure that we carry out the delivery of our services ethically and responsibly and working to prevent modern slavery and human trafficking throughout our organisation and in our supply chain.
CCL is committed to promoting environments that are free from human trafficking, forced labour and unlawful child labour. To permit any deviation from this position would not only be unethical but would also detract from our key organisational principles, including our commitment to the United Nations Global Compact.
CCL recognises that our moral obligation to the communities in which we serve means that we must lead by example across the healthcare sector in promoting and enforcing a zero-tolerance approach. We commit to promoting a culture at our healthcare facilities that encourages the prompt reporting and investigation of concerns about the welfare of any patient, family member or guest.
We also recognise the need for diligence within our supply chain (which is primarily UK-based but can extend globally). CCL will not tolerate slavery, servitude, forced or compulsory labour in the manufacture of products and services that we use or provide; and we will not partner with suppliers which employ or utilise slavery, servitude, forced or compulsory labour in any manner.
Organisation Structure and Supply Chain
Given our size and the range of specialisms in which we lead, we naturally buy a wide range of goods and services both in the provision and enabling of healthcare to our patients and to support our routine business. This can create complex supply chains.
Supply Chain function is responsible for on boarding and vetting of our suppliers, while Legal and Compliance departments support Supply Chain and other departments with significant third party exposure.
CCL takes a robust approach to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in its own enterprise or in any of its supply chains.
CCL is committed to promoting ethical and lawful employment and supply chain practices, and so our zero-tolerance approach to modern slavery extends to our suppliers, sub-contractors and business partners worldwide too. We require our suppliers to support our mission, and our core values of integrity, safety and quality, empathy, teamwork, innovation and inclusion. This is critical to fulfilling our mission and maintaining a healthy work environment.
Policies in Relation to Slavery and Human Trafficking
CCL has a number of policies and supporting procedures in this area including:
- Modern Slavery Policy.
- Safeguarding Children and Young People Policy.
- Safeguarding Adults at Risk Policy.
- Speaking up Policy.
- Code of Conduct.
Due Diligence Processes
We conduct supplier onboarding checks which include any prior convictions or allegations of modern slavery and trafficking.
In addition to onboarding checks, we must rely also on our suppliers taking this matter seriously too. Therefore, our diligence processes include confirming that our suppliers are similarly committed to combating modern slavery and human trafficking in their own businesses, and we reserve the right to ask for further information to verify the accuracy of information provided.
In 2023, we have critically examined whether our contractual due diligence processes are optimally designed to ensure appropriate scrutiny of prospective suppliers' understanding of their supply chains, and their own public statements on modern slavery and human trafficking.
In 2024 we will continue to work with Supply Chain and take action where necessary to demonstrate our zero-tolerance approach to modern slavery. This will include further enhancing our supplier vetting process, and procurement criteria to ensure we demonstrate a robust, risk-based approach to the modern slavery risks in onboarding suppliers. We will require our suppliers to acknowledge and comply with our Modern Slavery Policy.
We will also increase scrutiny of suppliers whose own supply chains may be more at risk of modern slavery.
Risk Assessment and Management
CCL employs a dedicated Safeguarding Lead who oversees safeguarding leadership at our healthcare facilities. We also employ a Compliance Officer and Freedom to Speak up Guardians and provide alternative anonymous reporting mechanisms for reporting incidents or suspicious activity. Accountability for the prevention of modern slavery rests with CCL's leadership team who have overall responsibility for this statement and for ensuring that policy, internal systems and controls are kept under regular observation to ensure that there is no gap between what we say we will do and what we actually do.
CCL's Speaking Up Policy and Code of Conduct remind all our colleagues about the various ways in which concerns about unethical behaviours (including modern slavery) can be raised without fear of reprisals, including directly to our Freedom to Speak Up Champions or via CCL's Reporting Concerns processes, where anonymous reports can be made. We offer colleagues at our healthcare facilities and other sites the opportunity to speak confidentially to the Speak Up Champions across the organisation. In the event that concerns were to be raised to the speaking up network about modern slavery, the Freedom to Speak Up Guardian would involve the Chief Nursing Executive and designated Safeguarding Lead to ensure CCL responds promptly and appropriately.
In 2024 we will continue to monitor closely modern slavery legislative developments, including preparing for anticipated updates within the UK Modern Slavery Act 2015.
We will also continue to engage with independent sector providers and NHS organisations by attending workshops, webinars and other events to increase awareness of modern slavery risks and promote learning and best practice within CCL to ensure that colleagues are appropriately trained to carry out their legislative, regulatory and ethical obligations in this area.
In addition, we will create a Modern Slavery Working Group with responsibility for ensuring continuous improvement in all activities described in this statement. The Working Group will be chaired by our Compliance Officer, and its members will represent all relevant areas of our enterprise.
Training on Modern Slavery and Trafficking
We recognise that in healthcare, modern slavery can manifest in a variety of ways, including the conduct, words and appearance of our patients and our patient's carers. Not least because our clinical colleagues may be exposed to examples of modern slavery, we make this topic a key part of our Compliance Programme.
Annual compliance training is mandatory for all our permanent colleagues, as well as many of our contractors. We make a commitment every year to ensure that this training draws explicit attention to the zero-tolerance approach towards modern slavery set out above. We remind colleagues of the typical signs of indentured labour. We remind all our colleagues of this online statement, and we explain why we do this — including referencing the wider themes contained within the Modern Slavery Act 2015. Attention is drawn to our policies and supporting procedures in this area. These topics are also discussed in other policies set out above including the Safeguarding Children and Young People Policy and the Safeguarding Adults at Risk Policy.
In 2023, we have continued to focus on modern slavery in our internal training, including how to report concerns (as described in detail above).
Our Safeguarding Lead maintains an intranet site which contains a policy and best practice library relating to modern slavery and safeguarding.
Summary
CCL's Compliance Programme reinforces the values set out in our Code of Conduct, which you can download at this page. The Code of Conduct emphasises the shared common values and culture that guide our actions: integrity, safety and quality, empathy, teamwork, innovation and inclusion. We pledge to treat all our colleagues, our customers with loyalty, respect and dignity.
In this spirit, this statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 31 December 2023. It was approved by the Board of CCL on 13 September 2024 and is signed by CCL's President.
We expect to update this annual statement next in January 2025.
Signed:
Robert Lorenz, MD
President of Cleveland Clinic London
Date: 13 September 2024
