Modern Slavery

1. 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.

2. Organisational Structure, Business and Supply Chains

KCH Interventional Facilities Management LLP (“KFM”) is a provider of healthcare support services, wholly-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. 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 has an annual turnover of around £150m and c300 staff.

3. 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:

  • Modern Slavery Policy
  • Code of Conduct
  • Supplier 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. During FY21, KFM put in place a corporate Modern Slavery Policy, which is designed to spell out KFM’s formal policy position on modern slavery and determines appropriate controls for countering modern slavery in our business and supply chains.

Recently, we approved our first Supplier Code of Conduct, which bans our suppliers from making use of modern slavery, in addition to prohibiting child labour.

4. 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.

In April 2021, KFM’s new e-sourcing and SRM system went live, which will further enhance our capability for auditing and assessing the effectiveness of upstream supply chain controls.

In addition to existing controls, KFM’s Modern Slavery Policy requires 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.

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