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Modern slavery and human trafficking statement

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If you need this policy in a different language, another format or any help reading this document, then please get in touch with the HR department.

Introduction

This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, sets out Ascenti’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 2016/2017. 

As part of the healthcare sector, Ascenti recognises that it has a responsibility to take a robust approach to slavery and human trafficking. Ascenti is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that those in its supply chains, and contractors, are free from slavery and human trafficking and comply with our values.

Organisational structure and supply chains

This policy covers the activities of Ascenti Health Limited, Ascenti Physio Limited, and File Dynamics Limited.

Ascenti is a provider of rehabilitation services providing services to insurers, employers, the NHS, personal injury and private patients, nationwide. Ascenti includes the organisation File Dynamics Limited, which provides support functions to the business. Ascenti’s head office is in Fareham but operates from numerous sites across the UK; in England, Scotland and Wales.

Ascenti’s supply chain mainly comprises physiotherapy and treatment providers that are instructed in order to provide physiotherapy and related services. Our supply chain also comprises suppliers as expected in the running of offices and physiotherapy and assessment clinics; including facilities services, recruitment agencies, training and equipment providers. The Ascenti Group currently only operates in the UK and collectively the Ascenti Group has an annual turnover in excess of £36m.

Risk Assessment Process

The following is the process by which Ascenti will assess whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • Annually, all senior managers of Ascenti will be asked by the HR department, to consider the following business risks, in order to assess and manage the risk to workers:
    • Country risks,
    • Sector risks,
    • Transaction risks,
    • Business partnership risks.
  • Any risks identified from the above process will be prioritised and dealt with in accordance with section 7.

High-risk activities

Ascenti does not believe it has any particular activities or is involved with any countries which are high risk in relation to slavery or human trafficking.

Responsibility

Responsibility for Ascenti's anti-slavery initiatives is as follows:

  • Overall: Ascenti Board
  • Policies: HR department.
  • Risk assessment, Due diligence and Training: Head of Quality

Relevant policies

Ascenti operates the following policies that describe its approach to the identification of
modern slavery risks and steps to be taken to prevent slavery and human trafficking in its
operations:

  • Whistleblowing policy: Ascenti encourages all its staff, clients and other business partners to report any concerns related to the direct activities, or the supply chains of, Ascenti. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Ascenti's whistleblowing procedure is designed to make it easy for staff to make disclosures, without fear of retaliation. Employees, clients or others who have concerns can complete our confidential disclosure form.
  • Employee code of conduct: Ascenti’s code makes clear to employees the actions and behaviour expected of them when representing Ascenti. Ascenti strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Environmental Management System: It is part of Ascenti’s on-going commitment to reduce the impact the company has on the environment by checking and monitoring suppliers and contractors standards through a third party questionnaire. This process of checking supplier standards can be expanded to include Human Trafficking and slavery checks to increase knowledge and confidence when dealing with suppliers and contractors.
  • Quality Management System: The Quality Policy sets out Ascenti’s commitment to high quality practices, including a collaborative partnership approach to working with our key suppliers. Our commitment to this approach allows us to have confidence in our suppliers’ commitment to preventing slavery and human trafficking in their operations, and those of their suppliers.

Due diligence

Ascenti has committed to undertaking due diligence when considering taking on new
suppliers, and regularly reviews its existing suppliers. Ascenti's due diligence and reviews will include:

  • Broadly considering suppliers to assess particular product or geographical risks of modern slavery and human trafficking;
  • When engaging a new frequent supplier as part of contract negotiations/tender processes, enquire if they are a business that is required to have a Modern Slavery and Human Trafficking Statement, and what policies they have in place;
  • Evaluating the modern slavery and human trafficking risks of each new supplier;
  • Where we identify high risk areas, explore those suppliers in greater detail;
  • Taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans;
  • Where a potential frequent supplier is unwilling to provide statements, or complete a questionnaire on the matter, consider if we commence that business relationship;
  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan, including the termination of the business relationship.

Performance indicators

In order to assess the effectiveness of our approach to modern slavery Ascenti will be
reviewing on an annual basis the following areas:

  • Training for staff
  • Staff awareness
  • Reviewing existing supply chains; and
  • Developing a new suppliers’ evaluation process.

Training

Ascenti will require all those staff involved in supply chain contracting and management to
complete training on Ascenti’s approach to slavery and human trafficking in order to better
understand and respond to the identified slavery and human trafficking risks.

Awareness-raising programme

As well as training staff, Ascenti will raise awareness of modern slavery issues via our intranet, explaining:

  • The basic principles of the Modern Slavery Act 2015;
  • How employers can identify and prevent slavery and human trafficking;
  • What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Company; and
  • What external help is available.