Modern Slavery Statement FY2020

11 Mar

Written By Sam Hemmings

Summary/Introduction
Modern slavery is a criminal offence and breaches fundamental human rights. Notwithstanding the provisions of the Modern Slavery Act 2015 (the “Act”), KFM is committed to eliminating modern slavery since this is the right moral course of action as a good corporate citizen.
Organisational Structure, Business and Supply Chains
KCH Interventional Facilities Management LLP (“KFM”) is a provider of healthcare support services. The purpose of KFM is to partner with and support healthcare providers in providing world class patient care, with all profits and cost savings re-invested in the NHS. KFM provides a fully managed service across all clinical areas which includes providing all required clinical supplies and equipment along with maintenance, training and technical support, endoscopy decontamination, sterile services, renal dialysis support, outpatients’ pharmacy, radiology IT, transformation and project management. KFM also runs a procurement and contract management service for all departments. KFM is a limited liability partnership (LLP) owned by King’s College Hospital NHS Foundation Trust (“KCH”) with no private sector partners. KFM is a public authority and not a private company. KFM has an annual turnover of around £150m and 250 staff.
Modern Slavery Policy Position
KFM takes a zero-tolerance approach to modern slavery and is committed to eradicating modern slavery from its business and supply chain. KFM has a number of policies in place designed to counter modern slavery within our organisation, which include:
- Code of Conduct
- KFM Values & Behaviours
- Raising Concerns (Whistleblowing) Policy
- Dignity at Work Policy
- Diversity & Inclusion Policy
- Recruitment and Selection Policy
  All procurement and contracting staff are furthermore required to acknowledge a professional code of ethics. KFM is presently working to put in place a corporate Modern Slavery Policy, which is designed to spell out KFM’s formal policy position on modern slavery and to determine appropriate controls for countering modern slavery in its business and supply chains.
Due Diligence
KFM is continuously reviewing and improving its due diligence processes relating to modern slavery.
KFM recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion once in our employment.
A key indicator that a person is not acting of his own free will in an employment situation include lack of access to his passport / immigration documents and being deprived of his wages by another person. To mitigate against this, all employees are at the point of recruitment required to present their passports and right to work documents, and salaries will only be paid into a bank account which is held in their name.
KFM is presently in the process of procuring a new e-sourcing and SRM solution, which will further enhance our capability for auditing and assessing the effectiveness of upstream supply chain controls. In addition to existing controls, KFM’s future Modern Slavery Policy will require modern slavery to be considered as part of a risk-based approach during the entire contract lifecycle, including the pre procurement and category plan development, tendering, selection, award and post-award stages.
Modern Slavery Risks
KFM has recently undertaken significant efforts to assess the modern slavery statements issued by KFM’s top 200 suppliers for compliance with the requirements of s. 54 of the Act. It was established that around 15% of modern slavery statements reviewed were not compliant. Frequently detected non-compliances include organisations failing to publish modern slavery statements, modern slavery statements being significantly out of date and lacking concrete information on the steps taken to counter modern slavery during last the financial year. As the initiative progressed, we began to query the information contained in some supplier modern slavery statements and senior KFM commercial staff continue to be in on-going conversations with senior supplier contacts, which we hope will encourage cultural change and lead to greater awareness of modern slavery amongst our supply base.
Our Commercial teams will conduct further work to categorise existing suppliers according to the modern slavery risk they represent.
Key Performance Indicators (KPIs)
Commercial staff are presently working to determine appropriate key performance indicators allowing KFM to assess the effectiveness of controls designed to counter modern slavery.
Training
All KFM staff are already receiving mandatory safeguarding training. During FY21, we will ensure that all staff involved with procurement and contracting receive formal training on countering modern slavery in supply chains.
This document represents KFM’s slavery and human trafficking statement under s. 54(1) Modern Slavery Act 2015 for the financial year ending on 31 March 2020 and was approved by the board of KCH Interventional Facilities Management LLP on behalf of its members on 24th August 2020.