Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
TFP, one of the leading fertility services providers across Northern Europe, is a network of IVF clinics, supported by satellites across 3 countries in Europe (the UK, Poland, the Netherlands).
We have long been established as a leading source of expertise in many aspects of reproductive health and regularly share best practice between clinics to deliver the very best chance of success to our patients.
TFP commits to taking a robust approach to reducing the risk of modern slavery occurring within our business or its supply chains and meeting the requirements of the “Act”.
We expect all our staff and suppliers to abide by all applicable laws and regulations and maintain the highest ethical standards. All staff are required to prove their eligibility to work in the UK, and DBS checks are carried out where applicable. Our supply agreements and contracts include provisions requiring them to comply with applicable laws and regulations, including as relates to the services, products or materials being supplied.
In particular, we commit to:
Ensuring that our staff are aware of the risk our business faces from modern slavery by incorporating training on this policy within the staff induction process and providing regular training as necessary
Assessing the risk of modern slavery and human trafficking occurring within a third-party supplier prior to entering into any business relationship (or in the event something changes)
Encouraging openness amongst our staff and suppliers and support anyone who raises genuine concerns regarding measures taken to be compliant with the Act
Being transparent with respect to the steps we are taking to meet obligations under the Act and publishing a modern slavery and human trafficking statement within 6 months of the end of each financial year
Review measures taken to be compliant with the Act on a regular basis and notify Third Party Suppliers of any changes.
As part of our initiative to identify, assess and mitigate risks we use a risk-based assessment process for evaluating, verifying and selecting direct suppliers during the formal process of tendering and evaluating suppliers. This process includes the completion of appropriate due diligence.
Going forward, we will implement measures to ensure that due diligence is conducted annually and that our suppliers, and the supply chain, still have the necessary policies and monitoring in place, thus ensuring that slavery and human trafficking are not taking place in any part of our business or supply chains. We will tailor appropriate remedial action on a case by case basis should there be any instances of non-compliance.
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training is provided as necessary.
Any employee who breaches this policy will 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.
TFP continues to assess and evaluate its supply chain’s responsible sourcing practices. We strive to enforce best practices in our supply chain and across the entirety of our organization.
Director of Delivery I Limited
(ultimate parent company for TFP)
Date: 22nd June 2020