Life UK Healthcare Limited (“LUHL”) is part of the Life Healthcare Group and is the UK holding company for a group of companies that operates in a number of countries including the UK. LUHL does not trade itself, the business in the UK is operated through its subsidiary companies Alliance Medical Limited (“AML”), Alliance Medical Radiopharmacy Limited (“AMRL”), Alliance Medical Leasing Limited (“AMLL”), Alliance Diagnostic Services Limited (“ADSL”) and the European Scanning Centre (Harley Street) Limited (“ESC”) (“AML, AMRL, AMLL, ADSL and ESC” together being referred to as the UK Entities).
UK Business Overview
AML is a provider of complex diagnostic imaging services, and has provided these services for more than 30 years either through itself or its other trading subsidiary ADSL. ESC is also a provider of complex diagnostic imaging services which utilises innovative and advanced scanning equipment. AMRL manufactures and distributes radiopharmaceutical products which are used in conjunction with the diagnostic imaging services. AMLL purchases scanning equipment that is used by AML at certain sites to provide its diagnostic imaging services and is the principal contracting party for construction and development contracts for certain new sites. The UK Entities work collaboratively with clinicians, public and private healthcare organisations and academic institutions to provide high quality and cost effective diagnostic imaging services and radiopharmaceuticals to its customers and for its patients.
The UK Entities’ supply chain includes procurement of scanning equipment and associated information technology equipment, transportation of mobile scanning units and radiopharmaceuticals, agency staff, medical and non medical consumables, and construction and maintenance of buildings.
The UK Entities are committed to combating the real and growing problem of modern slavery and human trafficking.
We recognise that it can affect any sector or industry and we take seriously our responsibility to be alert to the risks, however small, in our business and in our wider supply chain.
We expect our people and our suppliers to share our commitment to ensuring modern slavery and human trafficking do not exist in our business or supply chains.
The Life Healthcare Group have developed a Global Code of Conduct that incorporates references to combatting modern slavery and human trafficking which the UK Entities are committed to complying with.
We operate employment policies and procedures that are designed to treat all individuals who work within our business with dignity and respect, to reward them fairly for their work and not to exploit them.
We only wish to work with organisations in our supply chains that have a similar commitment and are not involved in modern slavery, or human trafficking and adhere to our values and principles
Whilst it is the obligation of those organisations to operate their own policies and procedures to achieve that objective, we will develop and build upon our existing practices to ensure we take all reasonable steps to verify compliance by all our material suppliers with the provisions of the Act.
Assessment of Risk within our Supply Chain
We have carried out a high level assessment of our supply chains and the potential for slavery and human trafficking. The vast majority of our suppliers are based in the UK and many are operating in specialised rather than low skilled industries and pose a lower risk in terms of compliance with the Act. However we recognise that some of our suppliers operate in sectors that are potentially higher risk and that some services may involve relatively high levels of contracted labour (for example textiles relating to staff uniforms). In addition, the COVID pandemic and the issues with the supply of personal protective equipment over the last 12 months also presents a higher risk that is recognised by the business.
We will continue to periodically review and re-assess the risks and are committed to procuring goods and services in a manner which recognises the importance of human rights; we expect all of our suppliers to honour and observe the same principles.
If we become aware that a supplier is non-compliant with our policies and contractual requirements relating to anti -slavery, we will, depending on the circumstances take action to terminate the arrangement without delay or work with the supplier to improve their performance.
Actions taken in the last 12months
- We have re-assessed the risks posed to the business in connection with the Act
- We have developed a supplier questionnaire that is to be adopted in respect of any material suppliers who are categorised as presenting a significant risk of modern slavery
- We have developed a supplier code of conduct for use with all material suppliers
- We have included contractual clauses in our supplier contracts and precedents which require our suppliers to provide undertakings to comply with the provisions of the Act
- We are in the process of developing a specific anti -slavery policy to evidence our commitment to the principles of the Act
Actions to be undertaken in the next 12 months
- To implement the anti-slavery policy evidencing our commitment to the principles of the Act
- To implement the supplier questionnaire for use with any material suppliers who are categorised as presenting a significant risk of modern slavery
- To implement the supplier code of conduct as part of the procurement process with all new material suppliers
- To obtain assurance from existing material suppliers in relation to their continued compliance with the Act, by requesting them to sign and accept the supplier code of conduct
- To introduce an overview of the Act and its principles in the employee induction programme for all new starters
- To introduce and deliver targeted training sessions to staff procuring goods and services. To continually review the provisions of the Act as applicable to our business activities
Approval by the Board of Directors
Each of the board of directors of the UK Entities has approved this statement for the financial year ending 30 September 2020
Pieter Van Der Westhuizen – Group Chief Financial Officer