Document Number: HCAUK.HR.HR.POL.1001
Publication Date: 04/01/2022
Review Date: 04/07/2024
Document Owner: Head of Employee
Expiry Date: 04/01/2025
Replaces Document: New document
Approved by: Vice President of Human Resources

Target Audience: All HCA Staff Date approved: 04/01/2022
Document Summary:
HCA Healthcare UK is committed to a work
environment that is free from human
trafficking, forced labour and unlawful child
labour (“human trafficking and slavery”).
This policy sets out the procedures to follow
in cases of suspected human trafficking.
Key words: Human Trafficking, Slavery, Suppliers
Key linked polices/ guidelines [Linked Policy Documents]
Version Tracking
Date Version Number Changes made to document
06/12/2016 1.0 New document reviewed and approved in Maximo.
21/10/2019 1.1 Policy under review, 6 month extension of review
agreed by Vice President of Human Resources.
April 2020 1.2 Policy extended due to Covid-19 pandemic April 2020
24/03/2021 1.3 Policy extended due to policy migration project 2021
04/01/2022 1.4 Policy reviewed as per process- minor amends only

Human Trafficking is a crime against humanity. It involves an act of recruiting, transporting
or transferring, harbouring, receiving or exchanging control over a person through a use of
force, coercion, abuse of vulnerability, fraud or deception or other means, for the purpose
of exploiting them.
HCA Healthcare UK (HCA) is committed to a work environment that is free from human
trafficking, forced labour and unlawful child labour (“human trafficking and slavery”). HCA
strongly believe that we are responsible for promoting ethical and lawful employment
practices. These practices are also required to be followed by HCA suppliers, subcontractors
or business partners (collectively referred to as “Suppliers”).

This policy applies to all HCA employees, including fixed term employees and Suppliers.

HCA will not tolerate slavery, servitude, forced or compulsory labour in our business, or in
the manufacture of products we use or sell, and will not accept products or services from
Suppliers who employ or utilise slavery, servitude, forced or compulsory labour in any
This policy defines how HCA will make efforts to eradicate human trafficking and slavery
from not only within the organisation but also from our global supply chains.

Servitude The state of being a slave or completely subject to
someone more powerful.
Forced or Compulsory Labour Any work or services which people are forced to do
against their will under the threat of some form
Human Trafficking The recruitment, transportation, transfer, harbouring
or receipt of persons, by means of the threat or use of
force or other forms of coercion, of abduction, of
fraud, of deception, of the abuse of power or of a
position of vulnerability or of the giving or receiving of
payments or benefits to achieve the consent of a
person having control over another person, for the
purpose of exploitation. Exploitation shall include, at a
minimum, the exploitation of the prostitution of others
or other forms of sexual exploitation, forced labour or
services, slavery or practices similar to slavery,
servitude or the removal of organs.

5.1 Employees
Employees are responsible for:
 being vigilant for signs of trafficking in patients;
 being vigilant for signs of trafficking in visitors;
 being vigilant for signs of trafficking in suppliers to HCA;
 reporting concerns to their Line Manager;
 complying with the Contracts Approval Policy.
5.2 Managers
Managers are responsible for:
 being vigilant for signs of trafficking in patients;
 being vigilant for signs of trafficking in visitors;
 being vigilant for signs of trafficking in suppliers to HCA;
 reporting any concerns relating to human trafficking to the Purchasing Team or Local
HR Team;
 educating their teams about slavery and human trafficking;
 complying with the Contracts Approval Policy especially when engaging with new
5.3 Suppliers
Suppliers are expected to:
 comply with the legal requirements as set out in the Modern Slavery Act 2015;
 comply with HCA’s Contracts Approval Policy and Supplier Code of Conduct to certify
that their work practices are ethical and do not breach legislation or this policy in
any way;
 allow HCA to carry out audits periodically to monitor compliance with this policy.
5.4 Human Resources Team
The Human Resources Team are expected to:
 act as a point of escalation when an employee has a concern about someone being a
victim of human trafficking;
 providing guidance on the implementation of the policy to Line Managers.
5.5 Purchasing Team
The purchasing team are expected to:
 act as a point of escalation when an employee has a concern about a supplier who
may be involved in human trafficking;
 providing guidance on the correct use of the Contracts Approval Policy and Suppliers
Code of Conduct;
 conducting supplier audits to monitor compliance with this policy.

6.1 Why are people trafficked?
The primary purposes for which people are trafficked are:
Sexual exploitation
Forcible or deceptive recruitment for prostitution or other forms of sexual exploitation.
Domestic servitude
Employment in private homes where ill treatment, humiliation and exhausting working
hours are common. This can also involve sexual and physical abuse.
Bonded/forced labour
In construction, agriculture, horticulture, marine farming, textiles, catering, nail bars, care
homes, and car washes, or any other industry. This can also include forced involvement in
illicit activities such as cannabis cultivation and pirate DVD selling.
Criminal activity
Including cannabis cultivation, street crime, forced begging and benefit fraud.
Organ harvesting
Organs are removed and sold on for profit.
Child trafficking
For begging, benefit fraud, illegal adoption, forced marriage, domestic servitude and sexual
exploitation. When children (i.e. under 18 years of age) are trafficked, no violence,
deception or coercion needs to be involved, simply transporting them into exploitative
conditions constitutes trafficking.
Often trafficked people have taken what is presented as a job opportunity, are lied to about
the work, pay and conditions, and subsequently find themselves in situations akin to slavery.
People are trafficked both internationally and within a country.
6.2 Signs of trafficking
HCA is a diverse organisation with employees, patients, visitors, bank workers and
Consultants from a variety of backgrounds. In order to comply with this policy it is
important that our employees are aware of the signs of human trafficking and know what to
do in the event they suspect someone might be a victim.
There are no definitive factors by which to identify trafficking, however, the following points
could indicate that someone is a potential victim of trafficking:
 the person has migrated locally or internationally for work commonly associated
with trafficking;
 the person is always accompanied by someone who appears controlling, who insists
on giving information;
 the person has no official means of identification or has suspicious looking
documents, or someone else is in possession of their identification or
documentation (e.g. passport, identification or travel documents);
 children and young people may have an unclear relationship with the accompanying
adult and give inconsistent information about their age.
The person:
 is withdrawn and submissive, seem afraid to speak to a person in authority and the
accompanying person speaks for them;
 gives a vague and inconsistent explanation of where they live, their employment or
 has old or serious injuries left untreated. Has delayed presentation and is vague and
reluctant to explain how the injury occurred or to give a medical history;
 is not registered with a GP, nursery or school;
 has experienced being moved locally, regionally, nationally or internationally;
 appears to be moving location frequently;
 their appearance suggests general physical neglect;
 they may struggle to speak English.
Trafficked people may not always self-identify as victims of trafficking. Trafficking victims
can be prevented from revealing their experience to health care employees from fear,
shame, language barriers and a lack of opportunity to do so. It can take time for a person to
feel safe enough to open up.
Possible healthcare issues of trafficked people:
 evidence of long term multiple injuries;
 indications of mental, physical and sexual trauma;
 sexually transmitted iInfections;
 pregnant, or a late booking over 24 weeks for maternity care;disordered eating or
poor nutrition;
 evidence of self-harm;
 dental pain;
 fatigue;
 non-specific symptoms of Post-Traumatic Stress Disorder;
 symptoms of psychiatric and psychological distress;back pain, stomach pain, skin
problems; headaches and dizzy spells.
6.3 What to do in the event of suspected trafficking
If an employee suspects someone is a victim of human trafficking they should seek advice
from the local HR team or, in the case of suppliers, the Purchasing Team before taking any
In all cases of suspecting human trafficking (including children, young people and adults),
HCA will seek to gather more information about the situation before considering involving
any third party. This will normally require speaking to the suspected victim in private,
without anyone who usually accompanies them.
If translation is necessary, only use an independent, qualified and police checked interpreter
or Language Line. Especially do not use anyone accompanying the person as an interpreter.
When speaking to someone who you believe may be a victim of human trafficking, consider
the following:
 make sure they are reassured that it is safe for them to speak;
 do not make promises that cannot be kept;
 only ask non-judgmental relevant questions;
 allow the person time to share their experiences;
 do not let concerns about challenging cultural beliefs stand in the way of making
informed assessments about the safety of a child, young person or adult;
 ensure the health needs of the person are addressed by continuing to provide care
(if applicable);
 react in a sensitive way that ensures the safety of the person; discuss any concerns
with the Local Safeguarding Lead who can provide support and advice;
 access additional external support if appropriate (see 6.4 below).
6.4 External Support
In the event it is established than an individual is likely to be, or confirmed to be a victim of
trafficking, it will be necessary to involve external agencies in order to ensure the matter is
handled correctly.
The National Referral Mechanism (NRM) is the process by which an individual is identified as
a victim of modern slavery. Referrals to the NRM can only be made by authorised agencies
known as ‘First Responder Organisations’. Authorised agencies in the UK are the police
force, the UK Border Force, Home Office Immigration and Visas, social services and certain
Non-Governmental Organisations.
If an individual is not considered to be in immediate danger, the local police station should
be contacted to discuss a referral to the NRM. However, if it is considered that someone is
in immediate danger, call 999. If you suspect modern slavery, report it to the Modern
Slavery Helpline on 08000 121 700 or the police on 101.
Support for adult victims of human trafficking is also available in England and Wales through
the Salvation Army. The Salvation Army has a 24-hour confidential helpline (0800 808 3733)
for professional advice and support and referrals which operates seven days a week. For
potential child victims of trafficking please call your Local Authority Children’s Services or
the NPSCC Child Trafficking Advice Centre on 0808 800 5000.
For further guidance on how to identify and support victims of human trafficking, please see
the booklet produced by the Department of Health which details guidance and actions for
healthcare employees who suspect that their patient may be a victim of human trafficking
(link below).

HCA is committed to a work environment that is free from human trafficking, as defined
within this policy.
HCA takes its responsibility for promoting ethical and lawful employment practices seriously
and these practices are also required to be followed by our suppliers, subcontractors or
business partners (collectively referred to as ‘Suppliers’) worldwide. It is the role of the
purchasing department to oversee and manage these practices.
In order to comply with this commitment, the Contract Approval Policy must be complied
with in the engagement and management of all suppliers. In order to comply with the
Contract Approval Policy, suppliers will also be required to sign the Supplier Code of
HCA has the right to terminate the contract of any supplier who does not comply with the
Supplier Code of Conduct. In the event HCA has serious concerns about a supplier in
relation to this policy, this may be referred to the Risk Advisory Group who will provide the
company with a detailed report on the supplier.
7.1 Requirements
HCA expects that our Suppliers:
 will not use forced or compulsory labour, i.e., any work or service that a worker
performs involuntarily, under threat of penalty;
 will ensure that the overall terms of employment are voluntary;
 will comply with the minimum age requirements prescribed by applicable laws;
 will compensate its workers with wages and benefits that meet or exceed the legally
required minimum and will comply with overtime pay requirements;
 will abide by applicable law concerning working times.
7.2 Certification
Suppliers will be expected to certify that materials incorporated into the products they
provide complies with the laws regarding human trafficking and slavery of the country or
countries in which they are doing business. All Suppliers will be required to sign a Supplier
Agreement to this effect. Signed agreements must be in place before any orders are placed
with a Supplier.
7.3 Audits
Suppliers must be able to demonstrate compliance with this policy at the request and
satisfaction of HCA.

The Human Resources Team is responsible for the implementation of this policy, along with
the Senior Management Teams at the corporate office and within each facility.
The policy will be distributed to the following groups:
Group Responsibility
Vice President of Human Resources Accountable for delivery
Director of Purchasing Accountable for delivery
Head of Employee Relations Review and implementation oversight
Purchasing Team Review and implementation oversight
Facility Human Resources Team Implementation
Facility Materials Team Information and support of process
Facility Senior Management Team Information and support of process
Line Managers Information and support of process
Employees Information

HCA is committed to monitoring Human Trafficking. HCA will monitor for cases of suspected
and actual human trafficking using the principles set out in this policy.

Training on the policy is delivered through the local HR team and the Purchasing Team

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