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.”
Code of Conduct Policies
All potential members and vendors are encouraged to read our stringent Code of Conduct, which applies to all employees and affiliates of HealthTrust Europe.
- Code of Conduct
- Conflict of Interest Policy
- Supplier Participation in HealthTrust Europe Conferences and Events Policy
- Business Courtesies given by HealthTrust Europe to Others Policy
- Business Courtesies received by HealthTrust Europe or HealthTrust Europe Colleagues from Others Policy
- HealthTrust Europe Colleague Participation in Educational, Training and Promotional Events of Others Policy
- HealthTrust Global Anti-Corruption Policy
- HCA UK Anti-Corruption Policy
- HCA UK Tax Strategy
- Eligible Contract Authorities
Find out more about the HCA Ethics and Compliance programme of which HealthTrust Europe is part here
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 due to open in Birmingham in 2023.
What is HCA UK’s position on modern slavery?
HCA UK is committed to promoting environments that are free from human trafficking, forced labour and unlawful child labour. To permit any deviation from this position would not only be unethical, it would detract also from our mission statement, which states that: Above all else, HCA UK is committed to the care and improvement of human life.
HCA UK recognises 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 promoting a culture at our hospitals and healthcare facilities that encourages the prompt reporting and investigation of concerns about the welfare of any patient, family member or guest.
We also recognise the need for diligence within our supply chain (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 that we use or sell; and we will not partner with suppliers which employ or utilise slavery, servitude, forced or compulsory labour in any manner.
What do we tell HCA UK colleagues about identifying and reporting workplace concerns around modern slavery and indentured labour?
We recognise that in healthcare, modern slavery can manifest in a variety of ways, including the conduct, words and appearance of our patients and our patient’s carers. Not least because our clinical colleagues may be exposed to examples of modern slavery, we make this topic a key part of our Ethics and Compliance Programme, which has the strapline: ‘Enabled, Transparent and True’.
Annual ethics and compliance training is mandatory for all our permanent colleagues, as well as many of our contractors and physician colleagues. We make a commitment every year to ensure that this training draws explicit attention to the zero-tolerance approach towards modern slavery set out above. We remind colleagues of the typical signs of indentured labour. We remind all our colleagues of this online statement, and we explain why we do this – including referencing the wider themes contained within the Modern Slavery Act 2015.
Attention is drawn to our policies and supporting procedures in this area. HCA UK’s 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. HCA UK’s Speaking Up Policy reminds all our colleagues about the various ways in which concerns about unethical behaviours (including modern slavery) can be raised without fear of reprisals, including directly 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 hospitals and other sites the opportunity to speak confidentially to the Freedom to Speak Up Guardian or to any one of more than 35 Speaking Up Champions across the HCA UK business. Where concerns have been raised to the speaking up network about modern slavery, the Freedom to Speak Up Guardian has always involved the Chief Nursing Executive and HCA UK’s designated Safeguarding Lead to ensure HCA UK responds promptly and appropriately.
In addition to mandatory annual training for all HCA UK colleagues, leaders in our business additionally receive bespoke learning which is tailored to their role and responsibilities in the business. This is refreshed every year to reflect current compliance and ethics trends in HCA UK’s business, 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 relating to modern slavery and human trafficking.
How do we work with our supply chain to ensure our zero-tolerance approach to modern slavery is a shared commitment?
HCA UK is 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 lead, 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 matter 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 to verify the accuracy of information provided.
What steps has HCA UK taken in 2022?
HCA UK continues to focus on demonstrating leadership in this area throughout our business. In the last year, we have taken the following steps.
- We created a Modern Slavery Working Group with responsibility for ensuring continuous improvement in all activities described in this statement. The Working Group is Chaired by our Ethics and Compliance Officer, and its members represent the following areas of our business: Legal, Supply Chain, Human Resources, Nursing, Governance, Paediatrics and Safeguarding. This Working Party has agreed terms of reference which included specific responsibility for ongoing policy improvement.
- We ensure that modern slavery and human trafficking reports are made in the standing agendas for all Ethics and Compliance Committees at all our HCA UK hospitals.
- We have critically examined whether our contractual due diligence processes are optimally designed to 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.
- HCA UK nursing and clinical leaders have led discussions within the Private Network Safeguarding Group to share good practice prevention and responding to cases.
- We have continued to embed our 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.
- We have responded appropriately to modern slavery concerns including referring matters to the appropriate authorities.
- We have continued to focus on modern slavery in our internal training, including how to report concerns (as described in detail above).
- Our Safeguarding Lead maintains an intranet site which contains a policy and best practice library relating to modern slavery and safeguarding.
What will HCA UK be doing in 2023?
With oversight from our Modern Slavery Working Group, HCA UK will continue to develop our processes, policy and reporting lines around modern slavery. In particular:
- We will continue to work with our supply chain and take immediate action where necessary to demonstrate our zero-tolerance approach to modern slavery. This will include further enhancing our supplier vetting process, and procurement criteria to ensure we demonstrate a robust, risk-based approach to the Modern Slavery risks in onboarding suppliers.
- We will increase auditing of suppliers whose own supply chains may be more at risk of modern slavery.
- We will continue to monitor closely modern slavery legislative developments, including preparing for anticipated updates within the UK Modern Slavery Act 2015.
- We will continue to engage with independent sector providers and NHS organisations by attending workshops, webinars and other events to increase awareness of Modern Slavery risks and promote learning and best practice within HCA UK to ensure that colleagues are optimally skilled to carry out their legislative, regulatory and ethical obligations in this area.
All HCA UK’s 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.
Who takes responsibility for our modern slavery programme?
HCA UK 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 HCA UK’s leadership team 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, and is signed by our President and Chief Executive Officer, HCA Healthcare UK President and Chief Executive Officer John Reay.
HCA International Limited (also referred to as “HCA Healthcare UK”, “HCA” and “HCA UK”) is a private limited company registered in England and Wales with registration number: 03020522. The registered office is situated at 2 Cavendish Square, London, W1G 0PU. Unless we say otherwise, we use the terms “HCA Healthcare UK”, “HCA UK”, “we”, “our” and “us” to refer to HCA International Limited throughout our website.
HCA International Limited makes this statement to comply with s.54(6) of the Modern Slavery Act 2015 on behalf of itself and all its Group companies (collectively referred to as ‘HCA UK’ in this statement). This statement is made in November 2021 and is updated in this version to reflect our priorities in this area for 2022.
Any queries relating to this statement can be directed to our Ethics and Compliance Officer at this email address: email@example.com
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.