Modern Slavery and Human Trafficking Statement

DermBiopsy Solutions Limited is committed to conducting its activities ethically, responsibly and with integrity. We have a zero-tolerance approach to modern slavery, human trafficking, forced or compulsory labour, servitude, debt bondage and the exploitation of workers.

Although DermBiopsy Solutions Limited is not currently required by its level of turnover to publish a statement under section 54 of the Modern Slavery Act 2015, we have chosen to publish this statement voluntarily. This reflects our commitment to responsible employment, effective safeguarding, ethical procurement and transparency as a provider of healthcare services to NHS organisations.

This statement describes the arrangements in place, and the further measures we are developing, to reduce the risk of modern slavery within our organisation and its supply chains.

DermBiopsy Solutions Limited is a CQC-registered healthcare provider delivering consultant-led skin biopsy and minor skin surgery services to adult patients.

Our services are primarily delivered through a hosted insourcing model within NHS hospital facilities. DermBiopsy Solutions supplies appropriately qualified and compliant clinical personnel, including consultant surgeons and registered nurses, while working alongside the governance arrangements, policies, safeguarding procedures and clinical systems of the host NHS Trust.

Depending upon the individual service agreement, the host NHS Trust will ordinarily provide the clinical premises, patient administration systems, medical records, pathology services, clinical equipment and consumables required to deliver the service.

Our own supply chain is therefore relatively limited. It may include:

• directly engaged clinical and administrative personnel;
• recruitment or staffing agencies, where used;
• professional advisers and business-support services;
• information technology, website and communications providers;
• training and occupational health providers;
• travel and accommodation providers; and
• other suppliers required to support the safe delivery and administration of our services.

Although we do not currently rely upon a complex international manufacturing supply chain, we recognise that modern slavery and labour exploitation can occur in organisations of any size and in any sector.

DermBiopsy Solutions will not knowingly enter into or continue a business relationship with any person or organisation involved in slavery, human trafficking, forced labour, unlawful recruitment practices or other forms of worker exploitation.

We are committed to:

• treating all employees, workers, contractors and applicants fairly and with dignity;
• ensuring that personnel are legally entitled to work in the United Kingdom;
• undertaking appropriate recruitment, identity and employment checks;
• not charging workers recruitment fees as a condition of engagement;
• not retaining original passports, identity documents or professional certificates;
• ensuring that remuneration and payment arrangements are transparent;
• enabling personnel to raise concerns without fear of victimisation;
• taking safeguarding concerns seriously;
• applying proportionate checks to suppliers and business partners; and
• responding promptly and appropriately when concerns are identified.

We recognise that recruitment and temporary or flexible working arrangements can present a potential risk of worker exploitation if they are not appropriately controlled.

Before any clinician or worker is deployed, DermBiopsy Solutions requires appropriate pre-employment and compliance checks. Depending upon the role, these may include:

• verification of identity;
• confirmation of the right to work in the United Kingdom;
• employment history and reference checks;
• Disclosure and Barring Service checks;
• verification of professional qualifications;
• confirmation of current GMC or NMC registration;
• review of professional restrictions or conditions of practice;
• occupational health clearance;
• confirmation of indemnity arrangements, where applicable;
• evidence of required statutory and mandatory training; and
• confirmation that the individual understands the relevant safeguarding and reporting arrangements.

Where a recruitment or staffing agency is used, DermBiopsy Solutions will seek assurance that the agency has completed the required employment checks and operates lawful and ethical recruitment practices.

Workers will not be required to pay DermBiopsy Solutions a recruitment fee in order to obtain work. DermBiopsy Solutions will not knowingly work with an intermediary that charges unlawful or exploitative recruitment fees, withholds a worker’s identity documents, subjects workers to coercion or makes improper deductions from their pay.

Any concern regarding the authenticity of documentation, unusual control by another person, unexplained deductions, restriction of movement, coercion or possible exploitation will be reviewed and escalated appropriately.

As a healthcare provider, DermBiopsy Solutions recognises that its clinical personnel may encounter patients who are experiencing, or are at risk of, exploitation, trafficking, domestic servitude, forced labour or other forms of abuse.

Clinical personnel are required to maintain appropriate safeguarding training and to remain alert to possible indicators of modern slavery. These may include:

• a person appearing to be controlled or closely monitored by another individual;
• reluctance or inability to speak without another person present;
• inconsistent explanations concerning employment, accommodation or injuries;
• possession of identity documents by another person;
• evidence of threats, coercion, violence or restriction of movement;
• untreated injuries, neglect or poor living conditions;
• excessive working hours or lack of control over wages;
• fear of authorities or immigration services; or
• another person insisting upon answering questions on the patient’s behalf.

Where a concern arises during the delivery of an NHS-hosted service, staff must act in accordance with the host Trust’s safeguarding procedures and immediately inform the appropriate Trust safeguarding lead or designated professional.

The concern must also be reported through DermBiopsy Solutions’ internal safeguarding and incident-reporting arrangements so that appropriate oversight, support and follow-up can be provided.

The safety and welfare of the individual will remain the primary consideration. Staff must not confront a suspected trafficker or take action that could place the individual, themselves or others at increased risk.

DermBiopsy Solutions maintains a governance framework intended to support ethical employment, safe clinical practice and the identification and escalation of concerns.

Relevant policies and procedures include:

• Safeguarding Adults Policy;
• Safeguarding Children Policy;
• Recruitment and Pre-employment Checks procedures;
• Equality, Diversity and Human Rights arrangements;
• Freedom to Speak Up and Whistleblowing arrangements;
• Incident Reporting and Investigation Policy;
• Complaints and Concerns procedures;
• Health and Safety Policy;
• Training and Development arrangements;
• Duty of Candour arrangements; and
• supplier and subcontractor assurance processes.

These policies are subject to document control and periodic review. Where DermBiopsy Solutions operates within an NHS Trust, staff must also comply with the applicable host Trust policies and escalation arrangements.

Where a DermBiopsy Solutions policy differs from a host Trust requirement, the matter will be reviewed before service delivery and the agreed arrangement communicated to the relevant personnel.

DermBiopsy Solutions applies a proportionate, risk-based approach when appointing suppliers, agencies and subcontractors.

The level of due diligence undertaken will take account of:

• the nature of the goods or services being supplied;
• whether labour is temporary, outsourced or subcontracted;
• the use of recruitment intermediaries;
• the supplier’s country of operation;
• the complexity and transparency of the supply chain;
• the vulnerability of the workers involved;
• any previous regulatory, legal or contractual concerns; and
• whether the supplier is required to publish its own modern slavery statement.

Depending upon the assessed risk, DermBiopsy Solutions may:

• request confirmation of compliance with the Modern Slavery Act 2015;
• review the supplier’s modern slavery statement or relevant policies;
• request information about recruitment and employment practices;
• require evidence of right-to-work and identity-checking arrangements;
• include modern slavery and ethical-employment obligations within contractual documentation;
• seek clarification of subcontracting arrangements;
• require the supplier to notify DermBiopsy Solutions of identified concerns; or
• undertake additional review before approving or continuing the relationship.

We expect suppliers and subcontractors to apply equivalent standards within their own operations and supply chains.

Where a modern slavery or labour exploitation concern is identified, DermBiopsy Solutions will consider the nature and seriousness of the concern and take appropriate action.

This may include:

• protecting and supporting the person who may be at risk;
• following safeguarding and incident-reporting procedures;
• informing the relevant host NHS Trust;
• seeking specialist safeguarding or legal advice;
• requiring a supplier to provide further information;
• agreeing and monitoring a corrective action plan;
• suspending further engagement or deployment;
• terminating the supplier or subcontractor relationship; and
• reporting the matter to the appropriate statutory authority.

Immediate danger or risk of serious harm should be reported to the emergency services by calling 999.

Other concerns may be reported to the police by calling 101 or to the Modern Slavery and Exploitation Helpline on 08000 121 700.

Employees, clinicians, contractors, applicants, suppliers and other individuals working with DermBiopsy Solutions are encouraged to report any concern relating to modern slavery, trafficking, coercion, unethical recruitment or worker exploitation.

Concerns may be raised with:

• the individual’s line manager or clinical lead;
• the DermBiopsy Solutions Safeguarding Lead;
• the Registered Manager or Nominated Individual;
• the host NHS Trust’s safeguarding team;
• the Freedom to Speak Up route, where applicable; or
• an appropriate external authority.

Concerns raised genuinely and in good faith will be treated seriously and sensitively. No person should experience retaliation or detrimental treatment for raising a genuine concern.

Confidentiality will be maintained as far as reasonably possible, although information may need to be shared where this is necessary to protect an individual or comply with safeguarding or legal responsibilities.

Relevant DermBiopsy Solutions personnel are required to complete safeguarding training appropriate to their role before deployment and to maintain that training in date.

Modern slavery awareness will be addressed through safeguarding, induction and governance arrangements. Personnel involved in recruitment, workforce compliance, procurement or supplier management will be provided with additional guidance appropriate to their responsibilities.

Training and guidance will cover, where relevant:

• common forms and indicators of modern slavery;
• risks associated with recruitment and temporary labour;
• how to respond to a disclosure or safeguarding concern;
• internal and host Trust escalation processes;
• the importance of accurate employment checks;
• confidential reporting arrangements; and
• the need to avoid actions that may increase risk to a potential victim.

DermBiopsy Solutions will monitor the effectiveness of its arrangements through proportionate indicators, including:

• the percentage of deployed personnel with completed identity and right-to-work checks;
• the percentage of deployed clinicians with verified professional registration and required pre-employment checks;
• the percentage of deployed personnel with current safeguarding training;
• the number and nature of modern slavery or labour-exploitation concerns reported;
• the action taken in response to any concerns;
• the number of higher-risk suppliers subject to enhanced review;
• identified breaches of supplier requirements; and
• the completion of annual policy and statement reviews.

These measures will be reviewed as the organisation grows and as its workforce and supplier arrangements develop.

During the period covered by this statement, DermBiopsy Solutions intends to:

• maintain robust pre-employment and professional compliance checks;
• strengthen the recording of supplier due diligence;
• incorporate proportionate modern slavery requirements into relevant supplier and subcontractor agreements;
• provide modern slavery awareness information to relevant personnel;
• review reporting and escalation arrangements;
• monitor developments in NHS and government procurement guidance; and
• review this statement annually.