ICG Medical recognises that all businesses have an obligation to prevent slavery and human trafficking and will do all in its power to do this within its business and the supply chains through which it operates.
Modern slavery can take many forms including the trafficking of people, forced labour, servitude and slavery. As leading recruitment experts, we take our responsibility for supplying staff extremely seriously and are aware of the potential for being targeted by traffickers and unlicensed gangmasters. Our own processes around candidate engagement ensure our employees are alert to the signs of exploitation, in order that we may take the necessary action promptly and effectively, should it be identified. Sectors affected include, but are not limited to, construction & property, engineering & manufacturing and health & social care.
This statement focuses specifically on ICG Medical’s compliance with the Modern Slavery Act 2015 (the Act) and highlights the steps we take to ensure there is no slavery or human trafficking occurring within the organisation or its supply chains. One of our Company’s most valuable assets has always been its reputation for integrity and fairness. Maintaining this reputation within our market is an essential pre-requisite to our continued success.
ICG Medical is a leading healthcare recruitment provider which delivers a blend of temporary, contract and permanent placements across the sector. Brands under the umbrella include the established Cromwell Medical Staffing and Imperial Medical Staffing, as well as newer, fast-growing brands Greenstaff Medical and Clinical24 Staffing.
ICG supports all brands under its umbrella with back office support which includes technology, human resources, finance, marketing, compliance, clinical governance and strategic direction.
ICG brands recruit and place healthcare professionals in both permanent and temporary positions. Geographies in which the brands operate are the UK, USA, Australia and India. Healthcare professionals are sourced from digital advertising, job boards, social media, recruitment events and customer referrals.
Our Supply Chains
Our supply chains include, but are not limited to, sourcing candidates for clients. This may involve the introduction by external agencies to ICG Medical of candidates for onward supply to our clients. We expect our suppliers and potential suppliers to aim for high ethical standards and to operate in an ethical, legally-compliant and professional manner. We also expect our suppliers to promote similar standards in their own supply chain.
Our Policies including on Slavery and Human Trafficking
Suppliers are expected to adhere to our Supplier Code of Conduct, which includes specific reference to the Act, and should have in place a policy recognising, respecting and protecting the human rights of their employees, those of their suppliers and business partners and the communities affected by the suppliers’ operations.
Employees should be free to choose to work for their employer and to leave the company upon reasonable notice.
All employees must be provided with a clear contract of employment, which complies with local legislation.
All employees must be treated in a fair and equal manner and with dignity and respect.
Any form of discrimination, victimisation or harassment on the grounds of marital or civil partnership status, sex (including gender reassignment), race (including ethnic, national origin and nationality), disability, sexual orientation, having or not having dependents, religious belief or political opinion, age, trade union activity and offending background should be prohibited.
All applicable laws and industry standards on employee wages, benefits, working hours and minimum age should be adhered to in all countries of operation, without any unauthorised deductions. Suppliers should observe the provisions of the International Labour Organization such that any young persons under the age of 18 should not be employed to work at night or for any hazardous work and their employment should not harm the young person’s education, health or physical, mental, moral or social development. No young persons may be employed below the age of 16.
All slavery and human trafficking laws must be complied with including, but not limited to, the Act. Suppliers must ensure their business operations are free from slavery and human trafficking practices whether in the UK or elsewhere, both internally and within their supply chains and other external business relationships. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Due Diligence Process for Slavery and Human Trafficking
ICG Medical ensure strict compliance checks are carried for all candidates it supplies. We verify the identity of each worker and their right to work before supply commences.
As part of our commitment to identify and eradicate slavery and human trafficking, we are undertaking due diligence on our supply chains to ensure compliance with legislative obligations and will continue and evolve this process in future years.
All ICG Medical employees have access to dedicated channels through which they may voice concerns, either through local reporting mechanisms or through the global whistleblowing procedure. ICG Medical is committed to protecting employees when disclosing malpractice and will ensure that all disclosures made in good faith will be treated confidentially and without fear of retaliation.
Any identified concerns regarding modern slavery and human trafficking would be escalated as part of the ICG Medical safeguarding process and in conjunction with the relevant agencies; such as the Local Authority and Police.
All staff within ICG Medical are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty. We have undertaken to review our policies and procedures to ensure our colleagues have access to any additional information and support they may require with regard to human trafficking, forced labour, servitude and slavery. Further training will be provided as required, which is an area that remains under review.
This statement is made to pursuant to Section 54 of the Act and constitutes ICG Medical’s slavery and human trafficking statement for the financial year ended 31 March 2018.
For and on behalf of ICG Medical and its subsidiary companies