Modality Partnership Modern Slavery Statement 2023/2024
Modern Slavery Statement 2023/2024
The Modern Slavery Act 2015 is designed to consolidate various offences relating to
human trafficking and slavery. The provisions in the Act create a requirement for an annual
statement to be prepared that demonstrates transparency in supply chains pertaining to
goods or services. In line with all businesses with a turnover greater than £36 million per
annum, and as a provider of services, the Modality Partnership provides the following
statement in compliance with the Act.
Our Business
We are a primary care Super Partnership that was established in June 2009. There are
currently over 40 practices as part of the group that form nine divisions (areas) across the
country in Birmingham, Walsall, Hull, Airedale, Wharfedale and Craven, East Surrey,
Wokingham, Lewisham, Mid-Sussex, and St Helens. Our vision is to become a leading
primary care provider locally nationally.
Assurance and our approach to Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our
supply chains or in any part of our business. Rigour in our recruiting processes and staff
welfare is our priority. Our Anti-Slavery approach reflects our commitment to acting
ethically and with integrity in all our business relationships, and to implementing and
enforcing effective systems and controls to ensure this is not taking place anywhere in our
business or within our supply chains.
This statement is published on our partnership website and contained within our staff
handbook.
Due Diligence and Processes
As part of our initiative to identify risk and mitigate against such risks, our National Board
and the Chief Executive Officer take responsibility through our management teams for
ensuring that our practices identify pertinent risks.
We have in place systems and approaches across our business, our trading partners and
our supply chains to:-
• Identify inappropriate employment practices including a robust approach to recruiting staff
into Modality Partnership that includes identity, DBS and qualification/reference checks,
and checks to ensure our people we recruit are legally entitled to work in the UK.
• Setting strict standards for conduct within the workplace, referencing this within our
contracting documentation and staff handbook for all staff as well as mirroring the NHS
code of conduct in respect of the expected standards for managers.
• Policies to guide staff on routes for whistleblowing, grievance, disciplinary and bullying
and harassment, providing them with assurance on our management role and providing
support with relevant workforce to support such policies, such as centralised HR
professionals, Wellbeing Champions and Guardians and Freedom to Speak Guardians.
• Through our mandatory training for all staff to raise awareness and responsibilities in
relation to the Act, and in particular towards our patients.
• Additional management training and wellbeing support awareness has been undertaken
and which will form part of mandatory management training to ensure all employees with
line management responsibility are consistent in their approach to staff recruitment,
employment rights and awareness and support to ensure the correct management of
employee welfare.
• Additionally, in acknowledgment of pressures which create extra demand on our services,
for example the COVID 19 Pandemic, and the increased seasonal demands on General
Practice, the recruitment of additional workers is a necessity to ensure safe service
delivery. Some of the additional required workers included voluntary workers, all of which
were recruited in line with the Modality Partnership recruitment policy. All volunteers that
provide support to our service provision are background checked in the same way as paid
employees who have pre-employment checks carried out.
Volunteers are issued with honorary contracts following their clearance checks, which also
includes rights to working in the UK and a DBS check. All volunteers are given the same
onboarding, induction, and site orientation as paid employees. Volunteers support the
service on a ad hoc basis and hours are monitored in line with working time directives to
ensure adequate rest breaks are provided.
Supplier and Procurement adherence to our values and ethics
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply
chain and contractors comply with our values, we operate in line with principles of
responsible sourcing. All members of staff have a personal responsibility for the successful
prevention of such practices taking place with our procurement department taking the lead
for compliance with our suppliers and those we contract with. The organisation is
committed to training our Procurement and Supplies Team on the implications of the Act
in order that they can support the wider organisation on its implementation.
The prevention, detection and reporting of modern slavery in any part of our organisation
or supply chain is the responsibility of all those working for us or on our behalf. Workers
must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a
breach in this area.
We are committed to engaging with our stakeholders and suppliers to address the risk of
modern slavery in our operations and supply chain. If we find that other individuals or
organisations working on our behalf have breached this policy, we will ensure that we take
appropriate action. This may range from considering the possibility of breaches being
remediated and whether that might represent the best outcome for those individuals
impacted by the breach to terminating such relationships.
The National Board of Directors has considered and approved this statement and will
continue to support the requirements of the legislation.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and
constitutes our slavery and human trafficking statement for the financial year ended 31
March 2024.
Vincent Sai
Modality Group Chief Executive
March 2024