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.”

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. HCA UK is committed to promoting ethical and lawful employment and supply chain practices. These practices are also required to be followed by our suppliers, sub-contractors and business partners worldwide.

HCA UK will not tolerate slavery, servitude, forced or compulsory labour 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 manner.

In order to detail our responsibilities, HCA UK has in place a Human Trafficking Policy which sets out the obligations on HCA UK colleagues, management and our supply chains to ensure that slavery and human trafficking does not occur.

Our mission statement and values

Above all else, HCA UK is committed to the care and improvement of human life.

In pursuit of this mission, 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. We make these commitments in our Code of Conduct which is provided to all HCA UK employees and is available via our website. The Code of Conduct provides guidance to ensure that everything we do is done in an ethical and legal manner and emphasises the shared common values and culture that guide our actions. It also contains resources to help resolve questions about appropriate conduct in the workplace.

HCA UK’s relationship with our supply chain

HCA UK requires our suppliers to support our mission, and our core values of honesty, integrity and fairness. Our zero-tolerance approach to modern slavery extends to our suppliers too. This is absolutely 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. Our due diligence processes seek confirmation from the supplier that they are compliant with the Modern Slavery Act 2015 (where that supplier has an annual turnover in excess of £36 million).


In order to detail our responsibilities in respect of modern slavery, HCA UK has in place a Human Trafficking Policy which sets out the obligations on colleagues, management and our supply chains to ensure that slavery and human trafficking does not occur. This is one of a number of policies in place to embed our Ethics & Compliance Programme. Adherence to these policies helps us to ensure that we are conducting business in an ethical and transparent manner. The other policies which cover Modern Slavery include, but are not limited to:

  • Code of Conduct
  • Speaking Up Policy
  • Human Trafficking Policy
  • Safeguarding Children and Young People Policy
  • Corporate Safeguarding Strategy
  • Safeguarding Adults at Risk Policy


On an on-going basis, our training programme includes bespoke annual learning provided to our leaders which is tailored to their role for the company. This is refreshed every year to reflect current compliance and ethics trends in our company, sector or in the communities in which we operate. All other permanent colleagues are required to complete annual ethics and compliance training. In all our ethics and compliance training, the theme of modern slavery is addressed, and attention drawn to our policies and procedures in this area.

Our focus for the next 12 months

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 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.

Responsibility for this statement

At HCA UK, we believe in setting the tone from the top. Responsibility 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 Boards of HCA International Limited and 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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