Modern slavery statement 2024
HCA Healthcare has been providing healthcare in the US for more than 50 years. In 1995, HCA entered the UK healthcare market through HCA UK and has built a network of over 30 facilities in London, Manchester and most recently The Harborne Hospital in Birmingham.
Has HCA UK's position on modern slavery changed during the year?
No, HCA UK remains committed to promoting environments that are free from human trafficking, forced labour and unlawful child labour. To permit any deviation from this position would not only be unethical, it would detract also from our mission statement, which states that: Above all else, HCA UK is committed to the care and improvement of human life.
HCA UK recognises that our moral obligation to the communities in which we serve means that we must lead by example across the healthcare sector in promoting and enforcing a zero-tolerance approach. We commit to promoting a culture at our hospitals and healthcare facilities that encourages the prompt reporting and investigation of concerns about the welfare of any patient, family member or guest.
We also recognise the need for diligence within our supply chain (which is primarily UK-based but can extend globally). HCA UK reaffirms that we will not tolerate slavery, servitude, forced or compulsory labour in the manufacture of products and services that we use or sell; and we will not partner with suppliers which employ or utilise slavery, servitude, forced or compulsory labour in any manner.
HCA UK recognises that the October 2023 King’s Speech included a Modern Slavery Bill, which may be debated in Parliament during 2024. We will be carefully scrutinising the passage of this Bill and we commit to meeting any new or amended reporting obligations in a spirit of transparency.
How does HCA train colleagues about modern slavery and indentured labour?
HCA UK recognises that in healthcare, modern slavery can manifest in a variety of ways, including the conduct, words and appearance of our patients and our patient’s carers. Not least because our clinical colleagues may be exposed to examples of modern slavery, we make this topic a key part of our Ethics and Compliance Programme, which has the strapline: ‘Enabled, Transparent and True’.
Annual ethics and compliance training is mandatory for all our permanent colleagues, as well as many of our contractors and physician colleagues. We make a commitment every year to ensure that
training draws explicit attention to the zero-tolerance approach towards modern slavery set out above. We remind colleagues of the typical signs of indentured labour. We remind all our colleagues of this online statement, and we explain why we do this – including referencing the wider themes contained within the Modern Slavery Act 2015.
Attention is drawn to our policies and supporting procedures which set out the obligations on colleagues, management and our supply chains to report concerns about slavery and human trafficking without delay. In particular, HCA UK’s Speaking Up Policy reminds colleagues about the various ways in which concerns about unethical behaviours (including modern slavery) can be raised without fear of reprisals, including directly to our Freedom to Speak Up Guardian, our network of Speaking Up Champions at hospitals, sites and facilities, or via HCA’s Ethics Line which allows anonymous reporting. We support the work of the National Guardian and contribute our data to the National Guardian’s office for aggregation across the healthcare sector.
Where appropriate, the Freedom to Speak Up Guardian will involve the local Chief Nursing Officer and HCA UK’s designated Safeguarding Lead in reviewing reports which are made in good faith. Nobody who reports a concern they hold in good faith will suffer detriment at work for speaking up.
In addition to mandatory annual training for all HCA UK colleagues, leaders in our business additionally receive bespoke learning which is tailored to their role and responsibilities in the business. This is refreshed every year to reflect current compliance and ethics trends in HCA UK’s business, sector and in the communities in which we operate. We make a commitment to keeping our leaders updated on relevant cases, law and best practice relating to modern slavery and human trafficking.
We have continued to embed our whole organisation Visitor Policy that includes clear expectation guidance regarding the family-employed staff or carers who accompany our patients to hospital. This is available in multiple languages and enables us to raise any concerns about possible domestic servitude with the carer as well as promoting patient safety.
How do we work with our supply chain to identify concerns about modern slavery?
HCA UK is committed to promoting ethical and lawful employment and supply chain practices, and so our zero-tolerance approach to modern slavery extends to our suppliers, sub-contractors and business partners worldwide too. We require our suppliers to support our mission, and our core values of honesty, integrity and fairness. This is critical to fulfilling our mission and maintaining a healthy work environment.
Given our size and the range of specialisms in which we lead, we naturally buy a wide range of goods and services both in the provision and enabling of healthcare to our customers and to support our routine business. This can create complex supply chains, and so we must rely also on our suppliers taking this matter seriously too. Therefore our diligence processes include testing that our suppliers are similarly committed to combating modern slavery and human trafficking in their own businesses, and we reserve the right to ask for further information to verify the accuracy of information provided.
What steps has HCA UK taken in 2023?
- HCA UK continues to focus on demonstrating leadership in this area throughout our business. In the last year, we have taken the following steps.
- Our Modern Slavery Working Group continued its work to focus on ensuring continuous improvement in all activities described in this statement. The Working Group is Chaired by our Ethics and Compliance Officer, and its members represent the following areas of our business: Legal, Supply Chain, Human Resources, Nursing, Governance, Paediatrics and Safeguarding. This Working Party has agreed terms of reference which included specific responsibility for ongoing policy improvement.
- At Portland Hospital (which is an HCA hospital with a wide paediatric offering) the appointment of a Safeguarding Sister has allowed us to develop training for clinical colleagues who may come into contact with patients’ carers. The Safeguarding Sister also acts as a point of contact for the carers, helping – for example – to ensure that they are able to take breaks and to provide opportunities for carers to enjoy social contact with others. The work of the Safeguarding Sister features in induction presentations for all new colleagues at the Hospital.
- We marked National Anti-Slavery Day on 18 October with an article on our Intranet written by the Ethics and Compliance Officer setting out the warning signs of modern slavery and reminding all colleagues – clinical and non-clinical - about the ways to report any concerns.
- Modern slavery and human trafficking reports are included in the standing agendas for Ethics and Compliance Committees at all our HCA UK hospitals and facilities.
- Working with our colleagues at HealthTrust Europe LLP, we continue to review our contractual due diligence processes to ensure that we give appropriate scrutiny to prospective suppliers’ understanding of their supply chains, including their own public statements on modern slavery and human trafficking.
- HCA UK nursing and clinical leaders have led discussions within the Private Network Safeguarding Group to share good practice prevention and responding to cases.
- Our Safeguarding Lead maintains a safeguarding information page on our intranet site which contains policy and best practice relating to safeguarding (including modern slavery).
What will HCA UK be doing in 2024?
- With oversight from our Modern Slavery Working Group, HCA UK will continue to develop our processes, policy and reporting lines around modern slavery. In particular:
- We will be widening the membership of our Modern Slavery Working Group to include new post holders.
- We will continue to work with our supply chain and take immediate action where necessary to ensure we demonstrate a robust, risk-based approach to the Modern Slavery risks in onboarding new suppliers, and in re-engaging with existing suppliers.
- We will increase auditing of suppliers whose own supply chains may be more at risk of modern slavery.
- We will be updating our Code of Conduct, including an expanded section on HCA UK’s commitment to maintaining a zero-tolerance approach to modern slavery.
- We will continue to monitor closely modern slavery legislative developments, including preparing for anticipated updates within the UK Modern Slavery Act 2015.
- As befits our commitment to leadership within healthcare, we will continue to engage with independent sector providers and NHS organisations by attending workshops, webinars and other events to increase awareness of sector-wide risks relating to modern slavery, and always to promote best practice – including for other companies.
- All HCA UK’s efforts will demonstrate our responsibility as a healthcare provider and enabler to share and promote best practice in all areas associated with physical and emotional well-being.
HCA UK employs a dedicated Safeguarding Lead who oversees safeguarding leadership at our hospitals and healthcare facilities. We also employ an Ethics and Compliance Officer and Freedom to Speak Up Guardian who is responsible for the delivery of our Ethics and Compliance Programme, including the promotion of HCA UK’s speaking up programme. Accountability for the prevention of modern slavery rests with HCA UK’s leadership team who have overall responsibility for this statement and for ensuring that policy, internal systems and controls are kept under continuous review.
HCA UK’s Ethics and Compliance Programme reinforces the values set out in our Code of Conduct, which you can download at this page. The Code of Conduct emphasises the shared common values and culture that guide our actions: we act with absolute honesty, integrity and fairness in the way we conduct our business, and we pledge to treat all our colleagues, our customers with loyalty, respect and dignity.
In this spirit, this statement is approved by the Board of HCA International Limited and is signed by HCA UK’s President and Chief Executive Officer.
We expect to update this annual statement next in February 2025.
February 2024
HCA International Limited (also referred to as “HCA Healthcare UK”, “HCA” and “HCA UK”) is a private limited company registered in England and Wales with registration number: 03020522. The registered office is situated at 2 Cavendish Square, London, W1G 0PU. Unless we say otherwise, we use the terms "HCA Healthcare UK", "HCA UK", "we", "our” and "us" to refer to HCA International Limited throughout our website.
HCA International Limited makes this statement to comply with s.54(6) of the Modern Slavery Act 2015 on behalf of itself and all its Group companies (collectively referred to as ‘HCA UK’ in this statement). This statement is made in February 2024 and is updated in this version to reflect our priorities in this area for 2024.
Any queries relating to this statement can be directed to our Ethics and Compliance Officer at this email address: ethicsandcompliance@hcahealthcare.co.uk
Previous Statements
Modern Slavery Statement FY2019
Modern Slavery Statement FY2020