MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction

This Modern Slavery and Human Trafficking statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 March 2025.

Crigglestone Dental ('we', 'us' or 'our') is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We maintain a zero-tolerance approach towards slavery and require our entire supply chain to comply with our values and ethical standards.

Organisational Structure

We operate in the dental healthcare sector. The nature of our supply chains is as follows: We work with a number of key direct suppliers who provide us with goods such as medical and dental equipment, PPE, and consumables for our premises, as well as services including outsourced business processes, IT software and infrastructure, facilities management, and marketing services.

Policies

We operate a comprehensive framework of internal policies to ensure that we conduct business in an ethical and transparent manner. These include:

  • Recruitment and Selection Policy - We conduct thorough eligibility and right-to-work checks on all employees, including enhanced DBS checks where required. We ensure all workers receive at least the Real Living Wage and maintain reasonable working hours with appropriate breaks and leave entitlements.

  • Whistleblowing Policy - We encourage all employees, contractors, and stakeholders to report any concerns through multiple reporting channels, with guarantees of confidentiality and protection from retaliation.

  • Staff Code of Conduct - We maintain clear standards against bullying, harassment, and discrimination, promoting mutual respect and dignity for all colleagues and stakeholders.

  • Safeguarding Policy - We have designated safeguarding leads within our organisation and maintain strong links with external safeguarding authorities within the wider NHS and local authority networks.

  • Supplier Code of Conduct - We require all suppliers to commit to ethical business practices and compliance with modern slavery legislation.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have implemented the following due diligence procedures:

  • Regular supplier audits and assessments

  • Contractual obligations for suppliers regarding modern slavery compliance

  • Staff wellbeing programmes and regular check-ins

  • Designated Caldicott Guardian for information governance

  • Annual modern slavery risk assessments

Our due diligence procedures aim to:

  • Identify and mitigate potential risks in our business and supply chains

  • Continuously monitor and assess risks in our operations

  • Reduce the likelihood of slavery and human trafficking occurring

  • Provide robust protection for whistleblowers

  • Ensure transparency in our supply chain relationships

Risk and Compliance

We regularly evaluate the nature and extent of our exposure to the risk of slavery and human trafficking through:

  • Annual risk assessments of our supply chain

  • Regular staff surveys and feedback mechanisms

  • Monitoring of recruitment practices

  • Review of supplier compliance documentation

While we do not consider ourselves to operate in a high-risk environment as a small healthcare organisation primarily employing UK-based dental professionals, we remain vigilant and committed to continuous improvement in our practices.

We maintain zero tolerance for slavery and human trafficking in our supply chains. Where there is evidence of non-compliance with our policies and procedures by any supplier or partner, we will take immediate action, including potential termination of the business relationship.

Effectiveness

We use the following key performance indicators (KPIs) to measure our effectiveness in ensuring that slavery and human trafficking is not taking place in our business and supply chains:

  • 100% of new suppliers assessed for modern slavery risks before engagement

  • Annual compliance declarations received from all existing suppliers

  • Number of staff trained on modern slavery awareness

  • Response rate to staff wellbeing surveys

  • Number of concerns raised and investigated through whistleblowing channels

Training and Awareness

During 2024-25, we have:

  • Provided modern slavery awareness training to all management staff

  • Included modern slavery compliance in our supplier onboarding process

  • Regularly communicated our commitment to ethical practices to all stakeholders

Next Steps

In the financial year 2025-26, we intend to take the following steps to further combat slavery and human trafficking:

  • Enhance our supplier verification processes with more detailed questionnaires

  • Implement digital tracking systems for supply chain transparency

  • Expand modern slavery training to all staff members

  • Develop partnerships with ethical sourcing organisations

  • Review and strengthen our KPI framework

  • Continue to monitor legislative developments and update our policies accordingly

Approval

This statement has been approved by the Board of Directors of Crigglestone Dental and will be reviewed and updated annually.