Ethics & Compliance

Recognised as an Ethical Company

HealthTrust Europe welcomes you to read below all the information and documentation related to our Ethics and Compliance standards and practices.

As a subsidiary of HCA Healthcare, HealthTrust Europe is recognised as an ethical company as part of the HCA Ethics and Compliance programme (link to HCA Page). In March 2022, the HCA Healthcare Group was named to Ethisphere’s World’s Most Ethical Companies for the 12th time.

“World’s Most Ethical Companies” and “Ethisphere” names and marks are registered trademarks of Ethisphere LLC.”

HCA Healthcare has been providing healthcare in the US for more than 50 years. In 1995, HCA entered the UK healthcare market through HCA UK and has built a network of over 30 facilities in London and Manchester, with its latest venture to open in Birmingham.

Slavery and Human Trafficking Statement

HCA International Limited and HealthTrust Europe LLP (HTE) make this statement to comply with s.54(6) of the Modern Slavery Act 2015 (collectively referred to as ‘HCA UK’ in this statement) in relation to the financial year ending 31 December 2021.

HTE operates as the UK arm of HealthTrust, a healthcare Group Purchasing Organisation that partners with both public and private sector healthcare providers to strengthen performance and clinical excellence to ultimately improve patient care. HealthTrust, HTE and HCA UK are collectively part of HCA Healthcare, one of the leading providers of healthcare services in the United States, comprised of more than 180 hospitals and 2,000+ sites of care in 21 states and the United Kingdom.

HCA UK’s position on modern slavery

HCA UK is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour.

Modern slavery and human trafficking are against HCA Healthcare’s values. We recognise that our moral obligation to the communities in which we serve means that we must lead by example across the healthcare sector in promoting and enforcing a zero-tolerance approach. We commit to doing this at our hospitals and other healthcare facilities in our everyday work; but we also recognise the need for diligence within our supply chain too (which is primarily UK-based but can extend globally).

HCA UK will not tolerate slavery, servitude, forced or compulsory labour in the manufacture of products and services 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 manner. We commit also to promoting a culture at our hospitals and healthcare facilities that encourages the proper reporting of concerns about the welfare of any patient, family member or guest.

Engagement of our people in our commitment to workplace that are free from modern slavery

We recognise that in healthcare, modern slavery can manifest in a variety of ways, including the conduct, words and appearance of our patients and their carers. For that reason, HCA UK recognises that all our colleagues need to know what to look for and how to report concerns. To achieve this, we give the topic prominence throughout our Ethics and Compliance Programme, including in our policies and the mandatory annual training for all staff and colleagues.

HCA UK has in place a number of policies to ensure that we are conducting business in an ethical and transparent manner. In particular, our Human Trafficking Policy sets out the obligations on colleagues, management and our supply chains to ensure that slavery and human trafficking does not occur. These topics are also discussed in other policies including the Safeguarding Children and Young People Policy and the Safeguarding Adults at Risk Policy.

Modern Slavery is a key part of our annual ethics and compliance training, which is mandatory for all our permanent staff. In this training, we emphasise our zero-tolerance approach towards modern slavery; and remind our colleagues of this statement and the requirements of the Modern Slavery Act 2015. Attention is drawn to our policies and supporting procedures in this area. Leaders in our business additionally receive bespoke learning which is tailored to their particular role in the company. This is refreshed every year to reflect current compliance and ethics trends in our company, sector and in the communities in which we operate. We make a commitment to keeping our leaders updated on relevant cases, law and best practice. In 2022, our training will focus on how to spot the indicators of modern slavery at our healthcare facilities.

HCA UK is proud to support the work of the National Guardian’s Office in promoting a speaking up culture across healthcare and recognises the responsibility the healthcare sector has to set this agenda across all sectors of society. Our Speaking Up Policy reminds all our people about the various ways in which concerns about unethical behaviours (including modern slavery) can be raised, including to our Freedom to Speak Up Guardian or via HCA’s Ethics Line, where anonymous reports can be made. We offer colleagues at all our hospital and other sites the opportunity to speak confidentially to the Freedom to Speak Up Guardian or to any one of our Speaking Up Champions. The work of our Guardian is overseen by Ethics and Compliance Committees at our facilities, ensuring that prompt executive attention can be given whenever necessary.

The Ethics and Compliance Programme reinforces the values set out in our Code of Conduct, which you can download at this page. The Code of Conduct emphasises the shared common values and culture that guide our actions: we act with absolute honesty, integrity and fairness in the way we conduct our business, and we pledge to treat our colleagues, our customers and our employees with loyalty, respect and dignity. Above all else, HCA UK is committed to the care and improvement of human life.

HCA UK’s relationship with our supply chain to ensure the zero-tolerance approach to modern slavery

We are committed to promoting ethical and lawful employment and supply chain practices, and so our zero-tolerance approach to modern slavery extends to our suppliers, sub-contractors and business partners worldwide too. We require our suppliers to support our mission, and our core values of honesty, integrity and fairness. This is critical to fulfilling our mission and maintaining a healthy work environment.

Given our size and the range of specialisms in which we excel, we naturally buy a wide range of goods and services both in the provision and enabling of healthcare to our customers and to support our routine business. This can create complex supply chains, and so we must rely also on our suppliers taking this issue seriously too. Therefore, our diligence processes include testing that our suppliers are similarly committed to combating modern slavery and human trafficking in their own businesses, and we reserve the right to ask for further information depending on their answers.

Taken steps of the HCA UK in 2020/2021

HCA UK continues to focus on demonstrating leadership in this area throughout our business. In the last year, we have:

•  refreshed our Modern Slavery training and ensured that it is mandatory for all HCA UK staff

•  celebrated Anti-Slavery Day on 18 October 2021 with a communication to all staff launching an anti-slavery section on out intranet site which contains a policy and best practice library relating to modern slavery and safeguarding

•  evaluated our contractual due diligence processes to better ensure appropriate scrutiny of prospective suppliers’ understanding of their supply chains, and their own public statements on modern slavery and human trafficking, including in their own supply chain

•  led discussions within the Private Network Safeguarding Group to share good practice prevention and responding to cases

•  developed a whole organisation Visitor Policy that includes clear expectation guidance regarding the family-employed staff or carers who accompany our patients to hospital. This is available in multiple languages and enables us to raise any concerns about possible domestic servitude with the carer as well as promoting patient safety

•  included contextual safeguarding, including modern slavery as a priority within our safeguarding strategy; and

•  responded to modern slavery concerns including referral of one ambulatory care case to the appropriate authorities.

Our focus for the next 12 months

We will continue to work with our supply chain and take immediate action where necessary to demonstrate our zero-tolerance approach to modern slavery. In addition, to reflect the increased focus on this topic in legislation and society, we continue to focus on modern slavery in our internal training, including how to report concerns.  Our training in this area includes increasing awareness of the practical signs of modern slavery and indentured employment which may be visible in a hospital and care setting and in our supply chain.

All our efforts will demonstrate our responsibility as a healthcare provider and enabler to share and promote best practice in all areas associated with physical and emotional well-being. To that end, we intend to develop a Modern Slavery Policy bringing together relevant clinical and non-clinical processes (including our existing policy and our bespoke training) in one place.

The topic of Modern Slavery is already discussed in all facilities’ Ethics and Compliance Committees; but we will ensure that regular reporting is made also to the Corporate Ethics and Compliance Committee. This Committee will supervise the creation of a Modern Slavery Working Group which will have responsibility for ensuring continuous improvement in all activities described in this document.

Responsibility for our modern slavery programme

HCA employs a dedicated Safeguarding Lead who oversees safeguarding leadership at our hospitals and healthcare facilities. We also employ an Ethics and Compliance Officer and Freedom to Speak Up Guardian who is responsible for the delivery of our Ethics and Compliance Programme. Accountability for the prevention of modern slavery rests with the Company’s leadership who have overall responsibility for this statement and for ensuring that policy, internal systems and controls are kept under regular observation to ensure that the there is no gap between what we say we will do and what we actually do.

In this spirit, this statement is approved by the Board of HCA International Limited, HealthTrust Europe LLP.

General Data Protection Regulation (GDPR)

Ensuring and maintaining the security and safety of personal and/or special category data belonging to the individuals with whom we deal with is paramount to our company ethos. HealthTrust Europe adheres to the GDPR and its associated principles in all processes and functions.

Our parent organisation HCA Healthcare UK has appointed a Data Privacy Officer who oversees the implementation of the GDPR within our corporate group; and our programme is well underway to ensure that we are ready for the new legislation when it takes effect.

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