Slavery & Human Trafficking Statement
For the year ended 31 December 2018.
In accordance with the Modern Slavery Act 2015, this statement provides an update on the commitment that Sharrow Dental Care makes to prevent slavery and human trafficking from taking place in our business and supply chains.
We aim for high standards of governance throughout our organisation and corporate responsiblity matters enormously to us. We recognise the responsibility we have towards our patients and other stakeholders, including our employees and society as a whole.
Sharrow is a family business operating out of three sites in the Chelmsford area and employing over 50 people. We deliver oral health services and dental services in the local community.
AF Clough Ltd is the ultimate holding company of the Sharrow Dental Care group.
Our commitment to combat slavery and human trafficking
Sharrow is strongly opposed to slavery and human trafficking and will not knowingly support or conduct business with any organisation involved in such activities.
Our direct workforce is predominantly made up of professionally qualified and skilled employees and we consider the risk of modern slavery occurring within our business to be low. All new employees are signposted to our employee handbook which includes a statement about our Code of Ethics and our Equal Opportunities Policy which makes it clear we oppose all forms of unfair discrimination or victimisation.
Our ethical standards
We promote high ethical standards and have an internal Whistleblowing policy whereby employees can raise suspected concerns regarding unethical behaviour or decisions that could indicate potential wrongdoing. We encourage employees to anonymously report any concerns and this is publicised widely.
Due diligence is undertaken before entering a new client/supplier relationship.
We recognise that training is crucial to raising awareness of issues around slavery including how to spot signs of trafficking and where to report concerns. We have plans in place to roll out awareness training for all employees on Modern Slavery as part of our induction/on-going staff training programme.
Sharrow relies on the use of third parties to support high quality, effective and efficient delivery of our services to clients and we expect all of our suppliers to operate in a responsible, ethical, open and transparent way and in compliance with all applicable laws and regulations.
As a healthcare provider with relatively simple supply chains predominantly comprising medical/dental supplies and professional services organisations, we believe that there is limited risk of slavery or human trafficking taking place. The vast majority of our major suppliers are head quartered in low risk countries.
Notwithstanding this, Sharrow is committed to developing initiatives to prevent slavery or human trafficking in its supply chains. We undertake robust due diligence on all material suppliers and summarily review and manage these relationships.
We take a risk based approach to supplier management and classification with criteria which includes business impact of failure, service complexity, regulatory requirements, brand/reputational impact and contract length used to determine appropriate on-going contract and performance management activities.
Initiatives being undertaken
In 2019 we hope to develop a new Supplier Relationship Management Policy to improve the governance of our relationships with suppliers and enhance the robustness of our procurement process. The policy will encourage partners to subscribe to a Code that assures us that forced labour and human trafficking are prohibited, together with the ethical and responsible sourcing of goods or services to be incorporated into the sourcing governance and execution processes of our suppliers.
This statement has been approved by the Boards of AF Clough Ltd and Anchor Street Care Ltd and will be reviewed and updated annually.
31 December 2018