Modern Slavery Act 2015

L'eto Clinic: Modern Slavery and Human Trafficking Policy

At L'eto Clinic, 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 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.

This Policy is made on behalf of L'eto Clinic pursuant to the Modern Slavery Act and constitutes our slavery and human trafficking Policy.

Our Supply Chains

L'eto Clinic's supply chain consists of over one hundred and fifty suppliers, the majority of whom are primarily based in the UK. Our suppliers include:

  • Professional services (accountants, legal advisors, recruitment agents)
  • Self-employed clinicians
  • Clinical laboratory, material, and product suppliers
  • Marketing and advertising services
  • Repairs and maintenance services
  • IT and communication systems
  • General office and practice suppliers

Due Diligence in Respect of Our Supply Chains

Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships, 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 in respect of new suppliers and commercial arrangements), we undertake a due diligence assessment taking into consideration the following factors:

  • Geographical location of the business or manufacture and supply of goods
  • Industry sector (we recognise that certain sectors suffer greater exposure to slavery and human trafficking practices)
  • Value of the contract or 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 or 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 suppliers 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 L'eto Clinic's approach, or be prepared to sign our Code of Conduct, we will cease to trade with their company until they have provided us with adequate reassurance of compliance.

General Due Diligence Processes

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. For example, we:

  • Continually monitor potential risk areas in our supply chains.
  • Protect whistleblowers 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 sixteen and above.
  • Collaborate with suppliers to help them understand and work towards their own obligations under the Modern Slavery Act.
  • 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.
  • Adopt a supply chain compliance programme, which consists of reviewing each new supplier in line with the principles of this Policy.
  • Recognise that some supply chains may operate outside of the UK; where appropriate, we work with third-party advisors and NGOs to ensure that due diligence is carried out pursuant to this policy.
  • Train our colleagues and business partners on their obligations under the applicable laws and regulations. Completion of our anti-slavery training module forms part of our annual training programme.
  • Will develop a procedure to monitor how our suppliers comply with our supplier Code of Conduct.
  • Pay and reward our employed colleagues in accordance with market rates, which are reviewed annually and benchmarked.
  • Provide our employed colleagues with enhanced benefits and welfare options to support our people’s (and their families') lifestyle choices.
  • Promote and encourage transparency within our supply chains.

Oversight and Effectiveness

We also have a dedicated compliance team which is responsible for ensuring that we comply with the principles and commitments set out in this Policy. Our compliance team consists of a Compliance Manager and a number of Compliance Facilitators, and they are supported by our Director of Business Operations and external professional advisors to ensure we act in accordance with the law.

Oversight of our approach is governed by a quarterly policy review board, chaired by the CEO and Founder of L'eto Clinic.

Our effectiveness in combating slavery and human trafficking within our organisation and supply chain is measured by reference to the number of reports received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

This Policy is made pursuant to the Modern Slavery Act and constitutes our slavery and human trafficking policy, reviewed by our Business Operations Director.