Modern Slavery and Human Trafficking Statement
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 ("the Act") and sets out Oasis Dental Care’s actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business or our supply chains.
As a leading provider of NHS and private dental treatment across the UK and the Republic of Ireland, Oasis Dental Care recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking and is committed to preventing such activity in its corporate activities including in its supply chains.
We were established in 1996, have over 377 practices across the UK and Republic of Ireland and care for more than 3 million patients. Our vision is to be recognised as the go to brand for dentistry – putting the patient at the heart of everything we do. We stand for Choice, Quality and Responsibility.
As one of the UK's largest dental care providers, we always work to the highest professional standards and comply with all laws, regulations and rules relevant to our business. Our corporate social responsibility strategy aims to ensure we make positive social, environmental and economic contributions across our business. Our published set of values support us in delivering our vision and underpins our ways of working and training and development activity. We are:
- Outcome Focused
Our supply chain relationships
Oasis Dental Care’s supply chain consists of over 3000 suppliers. Many of our suppliers and key partners are Pan European and Global organisations with whom we adopt a collaborative and open styled relationship. We ensure patient care is at the forefront of all of our business dealings. At present, we are not aware that any of our current supply chains are sourcing from high risk geographies.
Whilst, we do not believe we have any activities within our organisation which are considered to be at high risk of slavery or human trafficking, in light of the additional clause, referenced “Transparency in Supply Chain”, which was added retrospectively to the Act in October 2015, we will, by the end of our financial year March 2017 have finalised our Supply Chain Mapping Policy. This policy, which is currently under development, has been designed to outline Oasis Dental Care’s approach to our supply chain risk management review process. Our primary aim is to ensure a clear methodology for the management of risks in our supply chain and to minimise any adversity.
Our policies on slavery and human trafficking
Oasis Dental Care is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy reflects our commitment to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains or in any part of our business.
From a recruitment perspective, we have an in-house recruitment team which works closely with hiring managers to recruit our employees. The majority of our hiring is direct although we supplement this with recruitment agency support where necessary. We operate a parallel process for the engagement of all self-employed clinicians. Through robust screening and new starter administration processes, we evidence employees’ identity, career history and ensure their Right to Work.
We also have an established Whistleblowing Policy and Safecall Whistleblowing helpline which is available via the intranet and/or by calling 0800 915 1571; these are well publicised across our practices and support centre. If there are any genuine concerns about any wrongdoing or breaches of law, these concerns can be raised in confidence and without fear of disciplinary action under the Whistleblowing Policy. Our Whistleblowing Policy and CSR Policy have, at the point of publishing this statement, been updated in light of the Modern Slavery Act to make specific reference to slavery and human trafficking.
We are currently reviewing our internal processes to understand what further steps can be taken to ensure that our obligations under the Act are met and that our Anti-Slavery Policy is effectively implemented and complied with, so as to ensure that there is no slavery or human trafficking in any part of our business or our supply chains.
As part of this approach we will adopt a zero tolerance approach to modern slavery and human trafficking and we will communicate this to all our suppliers, contractors and business partners at the outset of any of our business relationships and we will reinforce our approach, where appropriate, thereafter. We will also cease to engage with individuals and organisations working on our behalf if they do not comply with our approach.
Whilst we are not aware of any modern slavery or human trafficking within our supply chains to date, if any come to our attention we will act immediately in accordance with our legal and moral obligations.
Our updated procurement process which is expected to be published by the end of November 2016 will include a procedure in which we will vet each new supplier and carry out a risk analysis based on the nature and value of the product or service.
All our suppliers are expected to comply with all local and national laws and regulations and we will therefore seek information about:
- Monitoring of tier 1 and 2 supply chains for unfair practices;
- Policies on fair sourcing of goods and services;
- Employment practices such as advertising vacancies, work/life balance;
- Training for staff;
- Diversity data;
- Corporate Social Responsibility; and
- Willingness to share our values.
Supplier responses are taken into consideration when short-listing and we make any concerns known to the supplier at that stage. Should suppliers fail to live up to our expectations or be unwilling to make any changes we may cease to engage with them.
We are currently reviewing our entire contracting process and our internal procurement policies and procedures to ensure that there is no slavery or human trafficking in our supply chains. We intend to take the following further steps to combat modern slavery and human trafficking and to ensure that our obligations under the Act are passed through our supply chains. Unless otherwise stated, we intend to take these steps by the end of November 2016:
- Obtain contractual warranties that no slavery is used anywhere in our suppliers' business or by any of the suppliers in their supply chain and that all necessary processes and policies have been put into place to ensure that this remains the case;
- Introduce or amend existing due diligence procedures so as to request information which will better inform our assessment of slavery and human traffic risk in our supply chain. This will be implemented by the end of March 2017;
- Obtain a contractual right to request compliance related information and a right to audit suppliers at our discretion; this will involve conducting periodic site visits and will be expected to be completed by the end of March 2017;
- Add indemnity provisions and rights to terminate for breach of our Anti-Slavery Policy into our contracts;
- Ensure risk areas are documented, monitored and taken into consideration in any future contract renewals;
- Ensure the Oasis Procurement Team are fully trained and aware of the risk by utilising CIPS (The Chartered Institute of Procurement and Supply) best practice guides and tools.
This statement relates to our actions and activities during the financial year 2015/2016 and plans underway for 2016/2017.
Chief Executive Officer
Oasis Dental Care