Modern Day Slavery Act Statement 2022
This statement is made on behalf of Healthwork and Optima Health Group Ltd and subsidiary companies; OH Assist Limited, Working on Wellbeing Limited, OH Assist Finance Limited, OH Assist Intermediate Limited, Healthwork Limited, Optima Health Limited (hereafter collectively “Optima”) pursuant to section 54 (1) of the Modern Slavery Act 2015 (the ‘Act’) and constitutes our slavery and human trafficking statement, for the current financial year (1 April 2022 to 31 March 2023).
Optima is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
Optima is a UK based occupational health services provider, focused on helping our clients deliver Healthy High Performance™. This means working in partnership with our clients to create a workplace culture that recognises employee wellbeing as being at the heart of business success. We deliver a comprehensive range of services via a nationwide network of practitioners (supported by two key operational service centres) including absence management, fitness for task assessments, health surveillance, vocational rehabilitation and wellness programmes.
Applying multidisciplinary expertise and deep industry knowledge, our Optima specialists work with predominantly UK clients from many market sectors, including central and local government, financial services, media, transport and logistics.
As a people-based service the majority of our suppliers are those providing clinical and professional expert resource or the supply of medical consumables.
The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
Optima operates a supplier policy and undertakes due diligence on all our suppliers. The due diligence includes a statement that each supplier is required to complete to show that the organisation:
- Complies with the Modern Slavery Act
- Takes steps to eradicate modern slavery from their business
- Holds their own suppliers to account over modern slavery
- Ensures their workers receive the minimum wage and undertake robust immigration checks
We may terminate the contract at any time should any instances of modern slavery come to light.
Optima does not consider it operates in high risk sectors or locations as we only operate within the UK and utilise predominantly professional clinical employees.
- Supplier/Procurement: Optima has a documented process for the sourcing and approval of third party suppliers to the organisation and has an Approved Supplier Register which documents all third party suppliers to the business. Suppliers are asked to complete a compliance statement to confirm their standards and compliance in quality, environmental aspects, health and safety, Modern Slavery Act, information security, equal opportunities and recruitment.
- Recruitment: Optima follows a documented Recruitment Policy and Procedure and have strict Security Guidelines in place to support the recruitment process. The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
- Grievances: Optima has a documented Grievance Procedure for the reporting of unlawful discrimination in any form.
- Whistleblowing policy: The organisation encourages all its workers to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistle blowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
- Anti slavery policy: This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where to go for help.
- Company Values: The organisation's values make clear to employees the actions and behaviour expected of them when representing the organisation.
The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:
- mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
- evaluating the modern slavery and human trafficking risks of each new supplier
- reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping
- conducting supplier audits or assessments through the organisation's own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified
- creating an annual risk profile for each supplier
- taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans
- invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship
The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation:
- requires Supply chain managers, Recruitment and HR professionals to have awareness of Optima Health’s statement regarding modern slavery
- has a system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain, and
- reviews existing supply chains to ensure ongoing compliance
Chief Executive Officer Approval
This statement has been approved by the organisation's Board of Directors who will review and update it annually.
Anti-slavery Policy Statement
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. This policy explains Optima Health Group’s approach to modern slavery and sets out what you should do if you believe that any modern slavery is taking place within our business or supply chain.
Optima Health has a zero approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
We accept that we have a responsibility to ensure, through our due diligence processes, and so far as is possible, that workers are not being exploited, that they are safe and that relevant employment, health and safety, and human rights and standards are being adhered to, we will notify the relevant authorities.
The prevention, detection and reporting of slavery in any part of Optima Health’s business or supply chain is the responsibility of everyone working for Optima Health. You must avoid any activity that may lead to a breach of this policy and should report any concerns immediately under the reporting procedure below.
If you believe or suspect that a breach of this policy has occurred or is occurring, you must report it by either speaking to your manager or by following the whistleblowing policy. You can also call the Modern Slavery Helpline for advice and guidance on 0800 0121 700.
Optima Health actively encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. You will not suffer any detrimental treatment as a result of reporting in good faith a suspicion that modern slavery is taking place in any part of the business or supply chain.
As Chief Executive Officer I take full responsibility to ensure that this policy is communicated and implemented throughout the organisation and any other interested parties.
Jonathan Thomas, Chief Executive Officer 1st October 2022