Modern Slavery Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) and sets out the steps taken by Acacium Group Limited, and the following entities in preventing modern slavery and human trafficking in its business and supply chains: Independent Clinical Services Limited, Pulse Healthcare Limited, Proclinical Limited, Liquid Personnel Limited and ICS Operations Limited.
In this statement the terms Acacium Group or the Group mean Acacium Group Limited and its subsidiaries, as defined in the Companies Act 2006.
This statement covers the calendar year 2023, which is also Acacium Group’s financial year.
Organisational Structure, Business and Supply Chains
The Acacium Group is the leading global healthcare delivery partner offering: staffing, managed services and innovative delivery models to health and social care systems and the global life sciences industry. It comprises market leading specialist brands, which combine workforce, services, deep clinical expertise, technology and analytics to deliver better outcomes for clients and patients.
At the Group’s core is its purpose to ‘improve people’s lives through expert healthcare, social care and life sciences’. This drives everything we do and extends to a commitment to act ethically and with integrity in all our business dealings and relationships. We report annually on our commitment to being a responsible business in our Responsible Business Report.
The nature of our business is that it is ‘people-driven’ and ‘tech-enabled’ with most Group spend being allocated to maintaining and building our workforce and the various technology systems and products we use to run our businesses and serve our customers. Whilst we do deliver certain healthcare services, which are regulated by the appropriate regulators in the UK, we do not operate any healthcare facilities. Our supply chain mainly consists of third-party recruitment and talent acquisition agencies, who may be engaged to support us to deliver to our clients, and other goods and services needed to operate our business such as IT and stationery.
Due Diligence Processes
Our principal business relationships are with the healthcare professionals and life science specialists who we introduce to, or deploy into, our clients’ businesses. We have extensive systems and processes in place as part of our recruitment, screening, and onboarding procedures, which, in part, serve to reduce the risk of candidates, who are victims of modern slavery or human trafficking, from being engaged by one of our businesses.
In terms of our supplier base, we risk assessed all suppliers for modern slavery risk. We then undertook a review of a cohort of c.20 potentially higher risk of suppliers (identified by category of supply (e.g. cleaning and merchandise suppliers), geography of operations (e.g. India) and level of Group spend) which comprised a desktop analysis and review of contract terms. For some suppliers our first stage analysis prompted further questions and we contacted each vendor directly to better assess any modern slavery risk. We did not identify any resulting issues, but if such an issue were to arise in the future, then we would look at alternative suppliers and either (depending on the circumstances and nature of the issue) immediately cease dealings with that supplier or work with them to get the necessary assurances to continue our engagement.
Risk assessment and management
Whilst our supply base is limited, and most of our business is carried out in countries that have a low prevalence of modern slavery (being Western Europe, the United States and Australia), we recognise that modern slavery is a complex global issue particularly relevant to (amongst others) the healthcare sector.
An internal working group was convened in 2023 with representation across Finance, Legal, Operations, People and Clinical Governance to review areas of modern slavery risk in the business (including the targeted supplier review outlined above) and reaffirm that we have appropriate mitigating factors in place to address these risks.
In terms of managing risks within our businesses, the controls in place as part of the recruitment, onboarding and deployment of workers are key. We also always seek to ensure appropriately robust modern slavery compliance obligations are included in our supplier contracts (and the successful implementation of a new contract management system has brought greater visibility and control of the Group’s commercial contracts). On the operational side, we believe that the Group’s safeguarding policies and requirements for front-line healthcare workers to have the appropriate level of safeguarding training are key to address front-line risk when workers are caring for vulnerable adults or young people. The support and tools available for colleagues and workers to raise concerns internally or, if preferred, via an independent confidential helpline, operated by Safecall, further helps to manage the risk of any such abuse going undetected or unreported.
Measuring effectiveness
We have continued to maintain a qualitative approach and not yet adopted any rigid performance indicators, which seek to determine how effective the Group is at ensuring slavery or human trafficking is not taking place in any of our businesses or supply chain.
Policies
The Group Clinical Director and Chief People Officer are responsible for the policy management, control and administration of the policy development process which includes: maintaining a central register of all policies, ensuring policies are reviewed in a timely manner, ensuring consistency through the policy development process, archiving superseded policies onto Acacium Group Pages and removing superseded policies.
Several Group policies specifically address the risk of modern slavery risk at a front-line level. The principal policies are the ‘Safeguarding and Protecting Adults at Risk Policy’ and the ‘Safeguarding and Protecting Children Policy’ (both reviewed biennially). These policies include detail on warning signs and how to escalate/report concerns. More broadly the Group has Whistleblowing Policies (updated in 2023) covering employees, workers and external partners. These are designed to encourage the raising of genuine concerns of wrongdoing or harm across our businesses. Other relevant policies include our Clinical Governance Policy, Recruitment and Selection Policy, Equality, Diversity and Inclusion Rights Policy and Complaints Policy.
Training
Training is essential to ensure our colleagues and workers understand this issue properly, and how to respond, in the context of their working environment. All Acacium Group employees complete an annual Modern Slavery training module and for all UK workers, who are healthcare practitioners, we follow the Royal College of Nursing’s Intercollegiate Document on Safeguarding and so require all such workers to have completed either Level 2 or Level 3 Safeguarding training as a pre-requisite to deployment.
This statement was approved by the Board of Directors of Acacium Group Limited on 25 June 2024.
Mike Barnard
Chief Executive Officer
27 June 2024
