Modern Slavery and Human Trafficking Statement

The Harley Street Pathology is firmly committed to combating modern slavery and human trafficking within our operations and supply chains. Here’s how we develop and maintain effective measures to mitigate these risks and build a responsible business environment:

Policies and Procedures

• Zero-Tolerance Policy: Our Modern Slavery and Human Trafficking Policy underlines a zero-tolerance approach to these crimes, promoting a strong ethical foundation in our operations.
• Whistleblowing Policy: We provide clear channels for employees, suppliers, and stakeholders to report any suspicions of slavery or human trafficking without fear of retaliation. We emphasize available UK Government and regulatory helplines for additional reporting options.
• Code of Conduct: Our Code of Conduct reinforces the importance of ethical behaviour, ensuring that all employees adhere to high standards and uphold these values when representing our organization.

Risk Assessment and Evaluation

• Annual Risk Assessment: We conduct comprehensive annual reviews of our supply chain using tools such as the Global Slavery Index to identify high-risk areas and vulnerable demographic groups. This review is supplemented by news analysis and the insights of human rights organizations.
• Country and Service Risk Profiles: We evaluate the risk profile of each country and type of service offered by our suppliers to tailor our response and implement appropriate controls.
• Continuous Monitoring: Regular updates and reviews of our risk assessments ensure that our understanding of potential threats is current and responsive to new developments.

Due Diligence Processes

• Supplier On-Boarding and Reviews: We carry out due diligence on all new suppliers and maintain regular assessments for existing suppliers. This process involves evaluating health and safety standards, employment practices, and labour relations.
• Auditing and Compliance Checks: Regular audits are conducted to verify that suppliers adhere to our anti-slavery standards. Substandard practices result in mandatory improvements and potential sanctions for non-compliance.
• Contractual Attestations: We require suppliers to confirm they do not use forced or compulsory labour, that their employees work voluntarily, and that they provide fair employment contracts and conditions. Suppliers are also required to ensure that workers retain control of their identification documents and are not subject to financial or contractual coercion.

Supply Chain Engagement

• Partnership Requirements: Our contracts include clauses that oblige suppliers to uphold anti-slavery standards. We emphasize collaboration and compliance to build a shared commitment to ethical practices across the supply chain.
• Improvement Protocols: When employment practices are identified as substandard, we work with suppliers to implement corrective measures. Persistent failure to comply results in termination of business relationships.

Training and Awareness Initiatives

• Employee Training: We provide targeted training to employees to recognize red flags and report potential cases of modern slavery. This training enhances their ability to identify suspicious activities and understand their role in prevention.
• Awareness Campaigns: Posters and email campaigns highlight our commitment to fighting modern slavery, reinforce key points on how to detect warning signs, and explain reporting procedures.

Communication and Reporting

• Transparent Reporting Systems: Clear channels are in place for employees and stakeholders to report concerns, bolstered by internal communication emphasizing confidentiality and support.
• Continuous Education: Regular updates on modern slavery issues ensure that staff remain informed and engaged, contributing to a culture of vigilance and action.

Future Commitment

• Policy Review and Enhancement: We regularly review our anti-slavery policies to enhance their effectiveness and adapt to new insights or legal developments.
• Collaboration with Human Rights Groups: We seek insights and recommendations from labour and human rights organizations to stay informed of best practices and improve our response.

Through these comprehensive measures, The Harley Street Pathology team reinforce their commitment to ethical operations and contribute to the global fight against modern slavery and human trafficking.