1. Our commitment

MSK Clinics Group is committed to acting ethically and with integrity in all our business dealings and relationships. Modern slavery is a crime and a violation of fundamental human rights. We have a zero-tolerance approach to slavery, servitude, forced or compulsory labour, and human trafficking in any part of our business or our supply chains.

As a healthcare group providing musculoskeletal care across our clinics, we recognise that we have a responsibility to the colleagues we employ, the patients we treat, and the suppliers and partners we work with. This policy sets out the steps we take to ensure that modern slavery is not taking place anywhere in our own operations or in those who provide goods and services to us.

2. Scope

This policy applies to all individuals working for us or on our behalf in any capacity, including employees at all levels, directors, officers, clinicians, locums and associates, agency and temporary workers, contractors, consultants, volunteers, and any other third party representing MSK Clinics Group.

It also informs the standards we expect of our suppliers, agencies, and business partners. We expect the same high standards from everyone in our supply chain, and we set out below what we ask of them.

3. About MSK Clinics Group

MSK Clinics Group is a musculoskeletal healthcare group operating clinics across the United Kingdom. Our clinical care spans all MSK disciplines. We operate across multiple locations and engage a range of suppliers and partners, including clinical and consumable suppliers, equipment providers, professional and marketing agencies, cleaning and facilities contractors, recruitment partners, and technology and software providers.

We consider the highest-risk areas in a business of our type to be the recruitment and engagement of labour (including locums, associates, and agency staff), facilities and cleaning services, and the sourcing of clinical consumables and equipment. We focus our due diligence accordingly.

4. What we mean by modern slavery

For the purposes of this policy, modern slavery includes:

• Slavery: the exercise of powers of ownership over a person.
• Servitude: an obligation to provide services imposed by coercion.
• Forced or compulsory labour: work or service exacted from a person under the menace of a penalty, and for which the person has not offered themselves voluntarily.
• Human trafficking: arranging or facilitating the travel of another person with a view to their exploitation.
• Child labour and the worst forms of child labour, and any exploitation of vulnerable people.

These terms are defined in, and this policy is informed by, the Modern Slavery Act 2015.

5. Responsibility for this policy

The Board of MSK Clinics Group has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that everyone under our control complies with it.

Day-to-day operational responsibility for implementing the policy sits with senior management, supported by colleagues in Human Resources, Operations, and Finance, who are responsible for monitoring its use and effectiveness, dealing with queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring that those reporting to them understand and comply with this policy and are given adequate and regular training on it.

6. Compliance with this policy

You must ensure that you read, understand, and comply with this policy. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of everyone working for us or under our control.

You must avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager, or use the reporting routes set out in section 10, as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

7. Due diligence and risk management

To identify and manage the risk of modern slavery in our operations and supply chains, we:

• Carry out right to work checks on all new colleagues, in line with our legal obligations, and confirm that each individual is being paid directly into their own bank account at or above the National Minimum Wage or National Living Wage.
• Assess modern slavery risk when engaging new suppliers, agencies, contractors, and recruitment partners, with particular attention to higher-risk categories such as agency labour, cleaning, and facilities services.
• Include anti-slavery and human trafficking expectations in our supplier and contractor arrangements where appropriate, and reserve the right to terminate relationships with any party found to be in breach.
• Maintain clear and accessible routes for colleagues, patients, suppliers, and the public to raise concerns.
• Review our policies, procedures, and controls on a regular basis.

We recognise that no organisation can entirely eliminate the risk of modern slavery in extended supply chains. Our approach is to identify, prioritise, and manage that risk in a proportionate and continually improving way.

8. Our suppliers and partners

We expect all suppliers, agencies, and business partners working with MSK Clinics Group to:

• Comply with the Modern Slavery Act 2015 and all applicable employment, health and safety, and human rights legislation.
• Not use any form of forced, bonded, compulsory, or child labour.
• Pay their workers fairly and on time, and not require workers to lodge deposits or identity documents as a condition of employment.
• Take reasonable steps to ensure that modern slavery is not taking place in their own supply chains.

We may ask suppliers to confirm their compliance, and we reserve the right to review their practices.

9. Training and awareness

We provide colleagues with information about modern slavery and human trafficking appropriate to their role, so that they understand the risks, can recognise the signs, and know how to raise a concern. Our commitment to addressing modern slavery is communicated to suppliers and partners at the outset of our relationship with them.

10. Raising a concern

If you encounter anything you believe may indicate slavery or human trafficking, whether in our own business or in our supply chains, you must report it.

Colleagues should raise concerns with their manager, with Human Resources, or through our whistleblowing procedure. You may raise a concern in confidence, and no one will suffer any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery is or may be taking place. If you believe that you have suffered any such treatment, you should inform Human Resources immediately.

Anyone outside the organisation, including patients, suppliers, and members of the public, can raise a concern by contacting us through the details published on our website.

If you believe someone is in immediate danger, contact the police on 999. Concerns about modern slavery can also be reported to the Modern Slavery and Exploitation Helpline on 08000 121 700.

11. Breaches of this policy

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

12. Review

This policy is reviewed at least annually and updated as required to reflect changes in our operations, our supply chains, and the legal and regulatory environment.