Effective Date: 1st July 2024
Last Updated: 1st July 2024

1. Introduction

1.1 Obsidian Healthcare Recruitment Ltd (“Obsidian Healthcare”, “we”, “us”, “our”) is committed to ensuring that modern slavery, human trafficking, forced labour, and all forms of exploitation have no place within our operations, supply chains, or business relationships throughout the United Kingdom. This Policy applies to all employees, contractors, agency workers, suppliers, clients, and other partners engaged with Obsidian Healthcare.

1.2 For the purposes of this Policy, modern slavery includes slavery, servitude, forced or compulsory labour, debt bondage, human trafficking, and the exploitation of vulnerable individuals for personal or commercial gain. Obsidian Healthcare strictly prohibits such practices in any form.

1.3 This Policy has been prepared in accordance with the UK Modern Slavery Act 2015 and all applicable UK labour, safeguarding, and human rights legislation.

2. Scope

2.1 This Policy applies to:
2.1.1 All employees of Obsidian Healthcare Recruitment Ltd.
2.1.2 All agency workers, candidates, and contractors supplied through our recruitment services.
2.1.3 All suppliers, subcontractors, and service providers engaged by Obsidian Healthcare.
2.1.4 Any joint ventures or business partnerships where Obsidian Healthcare exercises control.

2.2 Compliance with this Policy is mandatory for all individuals and partners. Continued engagement is conditional upon upholding these standards.

3. Our Commitment

3.1 Obsidian Healthcare is committed to:
3.1.1 Ensuring all employment practices follow UK employment law, including lawful working hours, fair pay, and safe conditions.
3.1.2 Ensuring no worker is subjected to forced labour, coercion, or exploitation within our operations.
3.1.3 Implementing recruitment processes designed to prevent modern slavery, including identity verification, DBS checks, right-to-work checks, and professional registration verification.
3.1.4 Expecting suppliers and business partners to uphold ethical labour standards. Contracts may be terminated if violations are identified.

4. Due Diligence and Risk Assessment

4.1 Obsidian Healthcare carries out ongoing due diligence to identify and mitigate risks of modern slavery, including:
4.1.1 Supplier assessments prior to engagement.
4.1.2 Requiring suppliers to demonstrate compliance with the Modern Slavery Act 2015.
4.1.3 Monitoring higher-risk sectors and roles in the healthcare and care-home sectors where workers may be more vulnerable.
4.1.4 Conducting periodic audits, reviews, and compliance checks.

5. Recruitment and Employment Practices

5.1 To prevent exploitation, Obsidian Healthcare has implemented strict measures, including:
5.1.1 Verification of identity, enhanced DBS checks, right-to-work checks, and professional registration checks (e.g., NMC, HCPC, GPhC).
5.1.2 Comprehensive reference checks before placement.
5.1.3 Ensuring no candidate is charged recruitment fees for temporary or permanent roles.
5.1.4 Providing all workers with clear written terms of assignment outlining rights and responsibilities.
5.1.5 Ensuring payroll is processed transparently, lawfully, and in compliance with UK tax and employment regulations.

6. Supplier and Partner Compliance

6.1 Obsidian Healthcare expects all suppliers and partners to comply fully with the Modern Slavery Act 2015.

6.2 Contracts require suppliers to confirm that:
6.2.1 No forced labour, servitude, or trafficking exists anywhere within their business.
6.2.2 All workers receive lawful pay, working conditions, rest breaks, and protections.
6.2.3 They maintain appropriate policies, training, and oversight to prevent exploitation.

6.3 Non-compliance may result in termination of the relationship.

7. Training and Awareness

7.1 Training is provided to staff involved in recruitment, compliance, and supplier management.
7.2 Staff are required to understand indicators of exploitation and the steps for reporting concerns.
7.3 All staff are reminded that concerns may be raised without fear of retaliation.

8. Reporting and Whistleblowing

8.1 Anyone who becomes aware of suspected modern slavery or human trafficking must report it immediately.
8.2 Reports may be made directly to management, the DPO, or through internal confidential channels.
8.3 Obsidian Healthcare will investigate all reports promptly, confidentially, and in accordance with UK law.
8.4 Retaliation against individuals reporting concerns in good faith is strictly prohibited.

9. Monitoring and Review

9.1 This Policy will be reviewed annually or earlier if required by changes in legislation or business operations.
9.2 Any identified breaches or concerns will trigger immediate investigation and corrective action.
9.3 Senior management is responsible for ensuring continued compliance and improvement.

10. Governance and Accountability

10.1 Overall responsibility for preventing modern slavery lies with the Board of Directors of Obsidian Healthcare Recruitment Ltd.
10.2 The Data Protection Officer and Compliance Officer oversee audits, reporting processes, supplier monitoring, and internal controls related to this Policy.
10.3 Violations of this Policy may lead to disciplinary action, termination of contracts, or legal proceedings.

11. Communication

11.1 This Modern Slavery and Human Trafficking Policy is publicly available on the Obsidian Healthcare Recruitment website.
11.2 All employees, candidates, and suppliers must acknowledge this Policy as part of their engagement.
11.3 Updated versions will be issued promptly when changes occur.

12. Contact Details

For concerns or queries regarding this Policy, please contact:

Obsidian Healthcare Recruitment Ltd
4 Minster Court
Tuscam Way
Camberley
Surrey
GU15 3YY
United Kingdom

Email: gdpr@obsidianhealthcarerecruitment.com
Telephone: 0208 068 7099

13. Approval and Review

13.1 This Policy has been approved by the Board of Directors of Obsidian Healthcare Recruitment Ltd and is effective as of 1st July 2024.
13.2 This Policy will be reviewed annually or sooner if required.