Legal information from Warwick Lodge Specialist Dentistry

Company structure

Warwick Lodge Specialist Dentistry is part of Portman Healthcare Ltd (trading as Portman Dental Care).

Portman Healthcare (Holdings) Ltd is a limited company registered in England, UK (registered company number 9114888).

Established in 2008, we provide privately funded dental care to patients throughout the UK through the brand of Portman Dental Care. Our business consists of a group of dental practices across the UK and was founded by Sam Waley-Cohen, who is the Chief Executive Officer.

Portman Healthcare Ltd (Company number 6740579) is the main trading company of the Portman Dental Care group. Other companies also trade under this brand. Our practices who trade under alternative trading companies all publish the relevant trading details in the footer of their individual practice website.

Portman operates as follows:

As at 1 April 2018:

• We had more than 75 dental practices operating across the UK
• We employ in excess of 900 employees
• We engage with over 300 dental consultants/ specialists
• We engage with approximately 2,500 suppliers per annum

Our ethos, vision and values

Our vision is to be the best private-focused dental group in the world. We aim to achieve this by:

• Putting patient care at the heart of everything we do
• Delivering innovative and world class dental care
• Always looking to develop and improve
• By being at the heart of every local community
• By being an amazing place to work

In respect of our colleagues, we have implemented a range of internal policies and procedures to ensure best practice and compliance with UK employment laws, e.g. these include; transparent recruitment processes, annual pay reviews, equal opportunities initiatives and protections, health and safety procedures.

Our central value is to treat everyone how we would want to be treated and we apply this principle to our colleagues, patients and third-party contacts.

As a group, we work to the highest professional standards and comply with all laws, regulations and rules which are relevant to our business. Our vision of being at the heart of the local community, aims to improve the impact of our business on the surrounding areas to our practices.

In turn, we expect the same high standards from those we work with and are committed to ensuring that there is no modern slavery or human trafficking practices in our supply chains or in any part of our business relationships. To help achieve this, and to ensure that our colleagues are aware of the role they can play, our Anti-Slavery Policy is published within all our practices and all teams are currently undergoing, or have undergone, training in this area.

We are committed to working with each of our practices to ensure that our Anti-Slavery Policy is complied with and we manage any breaches or concerns promptly. We have also amended our Whistle-blowing Policy to include guidance around combating anti-slavery and clarifying the protections available for employees who wish to raise a concern without the fear of disciplinary action.

Modern Slavery Act

At Portman, 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 dental 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 statement underlines our commitment and actions to ensuring modern slavery is not taking place anywhere in and around our organisation.

This statement is made on behalf of Portman pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.

Our supply chains

Portman’s supply chain consists of over 2,500 suppliers, the vast majority of whom are primarily based in the UK. Our suppliers include:

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

Suppliers paid over £10,000 per year make up 2.5% of our supplier spend and suppliers paid over £100,000 per year make up 0.5% of our supplier spend.

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/supply of goods
• Industry sector – we recognise that certain sectors suffer greater exposure to slavery and human trafficking practices
• Value of the contract / 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 / 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 supplier or business partners, we will not engage their services unless they share our values demonstrated in this Statement. 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 Portman Healthcare’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.

As at April 2017, we identified that:

• 100% of our direct suppliers were located within the UK or other low risk countries;
• 2.9% are companies in high-risk sectors such as hospitality and leisure, service, retail, construction, and food and beverage industries;
• 0.5% are greater than £100k of spend in the last 12 months;
• 0% are greater than £20k of spend in the last 12 months and are an overseas supplier.

General due diligence processes to combat slavery and human trafficking

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 whistle blowers 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 16 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 statement
• Train our colleagues and business partners on their obligations under the applicable laws and regulations. Completion of our anti-slavery training module will form 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 is reviewed annually and bench-marked
• 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

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

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

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 30 September 2017.

This statement was approved by our Board of Directors on 8 June 2017.