Introduction
We, Kingsbridge Healthcare Group Limited, are committed to improving our practices to combat slavery and human trafficking within our business and supply chain. This is our first year of producing a modern slavery statement on behalf of Kingsbridge Healthcare Group Limited (together “the Group”).
This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business and supply chain, and to implement steps to prevent slavery and human trafficking during the financial year 2025/2026. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.
Our business and supply chains
The Kingsbridge Healthcare Group Limited is the ultimate parent company of:
- Kingsbridge Private Hospital Belfast Limited;
- Kingsbridge Private Hospital North West Limited;
- Kingsbridge Opticians & Hearing Clinic Limited;
- Kingsbridge Private Hospital Sligo Ltd; and
- 352 Medical Limited (non-trading).
As of this financial year, two subsidiaries within the Group currently meet the reporting threshold under the Modern Slavery Act 2015 (namely, Kingsbridge Private Hospital Belfast Limited and Kingsbridge Private Hospital North West Limited). This statement has been produced on their behalf.
Background
The Group was originally founded in 2006 under the 3fivetwo Healthcare brand and is now the largest private healthcare provider in Northern Ireland. The Group operates across four locations in Northern Ireland and the Republic of Ireland.
Our supply chain
The Group’s supply chain varies from local SMEs to large global entities. The majority of the Group’s purchases come from suppliers based within the United Kingdom or the Republic of Ireland. However, over the next financial year the Group intends to conduct a supply chain mapping exercise of tier one suppliers.
We have not been made aware of any allegations of human trafficking/ slavery activities against any of our suppliers in this financial year, but if we were, then we would act immediately against the supplier and report it to the relevant authorities.
Policies
The Group operates the following policies relating to identifying and preventing slavery and human trafficking within our operations, of which we continuously review and update if appropriate:
- Whistleblowing Policy - we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. All reports received are fully investigated and appropriate remedial actions are taken.
- Grievance Policy – our policy allows all employees to voice any concerns and access remedies where appropriate.
- Anti-Bribery and Corruption – our policy demonstrates our commitment for acting honestly and ethically in our business dealings and outlines best practice and guidance for our employees.
- Purchasing Policy – our policy governs how our procurement staff deal with purchasing and supplier management and mandates annual supplier reviews. Through our review process for suppliers, various scoring factors are applied and such scoring includes an assessment of our supplier’s ESG impact and our supplier’s treatment of workers.
Due Diligence
The Group are committed to the prevention of slavery or human trafficking from taking place within our business and supply chain, to the best of our ability, though the following actions:
1. Undertaking a risk assessment of areas within our businesses and supply chain, with a particular focus on child labour, forced labour, health and safety, employment rights and diversity;
2. Complying with all local and international employment laws where we do business and operate in;
3. Performing due diligence on existing business partners, as well as with potential future business partners to notify our suppliers of our approach to human rights and working conditions;
4. Undertaking an audit of our supply chain and issuing a Modern Slavery Act questionnaire to our audit sample; and
5. Creating a safe and healthy work environment for our colleagues and notifying our expectation of a similar approach by our suppliers – specifically so that they comply with all applicable health and safety laws and regulations in the countries in which they operate.
Risk assessment
Through our risk assessment, in addition to our supply chain, we consider that potential risk areas in relation to modern slavery are agency workers and cleaning services and these are key areas which our business should monitor in order to limit the risk of slavery and human trafficking.
We have used data from the Global Slavery Index to identify any high risk countries where our business and/ or suppliers may operate in or recruit workers from. We intend to audit a sample of these suppliers annually to identify whether they present any concerns regarding modern slavery.
Training
This year we have engaged externally lead training sessions (through external law firm A&L Goodbody Northern Ireland LLP) for staff on the issue of modern slavery within our supply chains and our business. This training will be delivered to all members of the Senior Executive Board across the Group. We intend for this training to be developed and delivered to all members of the senior management team across the Group over time. Eventually, we intend to deliver training on modern slavery to all new starts as a part of their induction training.
In addition to specific training on the issue of modern slavery, members of our procurement department are currently in process of attaining membership and accreditation by the Chartered Institute of Procurement & Supply (CIPS), the world’s largest organisation dedicated to the ethical procurement and supply profession.
Measuring how we're performing
In order to continue to do all that we reasonably can to ensure that modern slavery or human trafficking does not occur within our supply chain, we intend to measure our performance against the following KPIs in the forthcoming financial year:
- The number of suppliers completing our modern slavery audit questionnaire;
- The number of ‘high-risk’ suppliers and agencies audited;
- Completion rates for modern slavery awareness training; and
- The number of modern slavery concerns identified and remediated.
These KPIs are evaluated on a regular basis and are reviewed by the Group’s Supply Chain Manager.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group's slavery and human trafficking statement for the financial year 2024/2025.This statement was approved by the board of Kingsbridge Healthcare Group Limited at the board meeting on [date].
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