St John’s Dental Practice 

Modern Slavery & Human Trafficking Act Policy

At St John’s Dental practice, we are committed to improving our practices to combat modern slavery and human trafficking within our business operations. We are relentless in our pursuit of delivering quality and excellent dental care to our patients, using our professional expertise with integrity and aligning our actions to the highest standards of business conduct and ethical practices.

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.

Application of provision 54 — Transparency in supply chains

Accessing our supply chains:

Our anti-Slavery and human trafficking policy reflects our commitment to acting ethically and with integrity in all our business relationships, suppliers, staff, 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 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 St John’s Dental Practices approach, or are prepared to follow our policy on modern slavery and human trafficking policy, 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 at St John’s dental practice. 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
• Train our colleagues and business partners on their obligations under the applicable laws and regulations. 
• 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.
• Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary

Our Code of Conduct and Anti-Slavery Policy contain specific provisions on human rights, employment rights and anti-slavery practices which is discussed with new employees on induction and generally, as part of ongoing training in the practice.