Modern slavery is a crime and a violation of fundamental human rights. This Policy underlines our commitment and actions to ensuring modern slavery is not taking place anywhere in and around our organisation.

This Policy is made on behalf of Wapping Dental Centre pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking Policy.

Our supply chains

Wapping Dental Centre supply chain consists of over 50 suppliers, the majority of whom are primarily based in the UK. Our suppliers include:
Professional services – accountants, legal advisors, recruitment agents;

• Self-employed clinicians;
• Dental laboratory, material and product suppliers;
• Marketing and advertising services;
• Repairs and maintenance services;
• IT and communication systems;
• General office and practice suppliers;

Accessing our supply chains

Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships, and implementing and enforcing effective systems and controls to prevent slavery and human trafficking practices in our supply chains.
To help identify any potential risks within our supply chains (including in respect of new suppliers and commercial arrangements), we undertake a due diligence assessment taking into consideration the following factors:

• Geographical location of the business or manufacture/supply of goods;
• Industry sector – we recognise that certain sectors suffer greater exposure to slavery and human trafficking practices;
• Value of the contract / commercial arrangement;
• Supplier’s dependency upon our business;
• The supplier’s own commitment to ethical practices, e.g. commitment to equal opportunities and diversity in the workplace, anti-slavery practices, compliance with the national minimum wage and national living wage, anti-bribery practices etc.

In the event that any supplier / commercial arrangement is considered to be a potential risk, we will undertake further due diligence until we are satisfied that we have achieved compliance with the law and ethical practices.

For all new supplier or business partners, we will not engage their services unless they share our values demonstrated in this Policy. Should any supplier fail to meet these standards, we will offer to help them identify the steps they will need to take to comply.

We are advising suppliers that we are adopting a zero-tolerance approach to modern slavery and human trafficking, and should any supplier or business partner not comply with Wapping Dental Centre’s approach, or be prepared to sign our Code of Conduct, we will cease to trade with their company until they have provided us with adequate reassurance of compliance.

General due diligence processes to combat slavery and human trafficking

We have also put in place systems, procedures and best practices to help combat anti-ethical practices and modern slavery within our supply chains and general business operations. For example, we:

• Continually monitor potential risk areas in our supply chains;
• Protect whistle blowers to ensure that they are not discouraged from raising any concerns relating to unethical or illegal practices;
• Ensure supplier adherence to our values and ethics;
• Adopt robust recruitment processes in line with UK employment laws, including: ‘right to work’ document checks; contracts of employment and checks to ensure everyone employed is 16 and above;
• Collaborate with suppliers to help them understand and work towards their own obligations under the Modern Slavery Act 2015;
• Engage with reputable businesses and individuals with a proven track record of legal compliance and good ethical standards;
• Have robust policies in place to ensure the new joiner has the Right to Work in the UK, and have confirmed their identity prior to the commencement of their placement;
• Adopt a supply chain compliance programme, which consists of reviewing each new supplier in line with the principles of this Policy;
• Train our colleagues and business partners on their obligations under the applicable laws and regulations. Completion of our anti-slavery training module will form part of our annual training programme;
• Will develop a procedure to monitor how our suppliers comply with our supplier Code of Conduct;
• Pay and reward our employed colleagues in accordance with market rates, which is reviewed annually and bench-marked;
• Promote and encourage transparency within our supply chains.

We also have a dedicated compliance team which is responsible for ensuring that we comply with the principles and commitments set out in this Policy. Our compliance team consists of Compliance Officers and are supported by our Head of Operations and external professional advisors to ensure we act in accordance with the law.

Our effectiveness in combating slavery and human trafficking within our organisation and supply chain is measured by reference to the number reports received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

This Policy is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking reviewed by Kayley Roberts, Head of Governance, Compliance & Contract Management, January 2022