Policy brief & purpose
Our Environmental and Corporate Social Responsibility (CSR) company policy refers to our responsibility toward our environment. It also includes our Modern Day Anti-Slavery (MDS) programme and Anti-Bribery & Corruption policy, to demonstrate that we don’t engage suppliers or partners who support human trafficking, slavery, kick-backs and fraudulent activity.
We have these programmes because our Clinic’s existence is not lonely. It’s part of a bigger system of people, values, other organisations and nature. The social responsibility of a business is to give back to the world just as it gives to us. As a healthcare practice, we want to be sure that we look after our patients and all peoples associated with our partner companies and supply chains.
This policy applies to our company. It may also refer to our suppliers and partners, who are encouraged to provide copies of their CSR policies when entering into trading positions or SLA’s with us.
We want to be a responsible private practice that meets the highest standards of ethics and professionalism.
Our company’s social responsibility falls under three categories: (i) compliance, (ii) proactiveness and (iii) modern day anti-slavery. Compliance refers to our company’s commitment to legality and willingness to observe community values. Proactiveness is every initiative to promote human rights, help communities and protect our natural environment. Anti-slavery considerations ensure our work force or suppliers teams are not exploited anywhere in the world.
Our company will:
*Observe the Law and specific regulations of clinical governance placed on us by professional bodies and insurers.
*Honour its internal policies
*Ensure that all its business operations are legitimate
*Keep every partnership and collaboration open and transparent
We’ll always conduct business with integrity and respect to human rights.
We actively promote:
*Safety and fair dealing
*Respect toward the consumer
*Anti-bribery and anti-corruption practices
Examples of our Corporate Social Responsibility
*Protecting the environment
Our company recognises the need to protect the natural environment. Keeping our environment clean and unpolluted is a benefit to all. We’ll always follow best practices when disposing sharps, clinical waste, non-clinical waste and using chemical substances.
We’ll ensure that we:
*Don’t risk the health and safety of our employees and community. We communicate health and safety (and fire risk safety) via initial induction training, periodical retraining and verbal communication as indicated.
*Avoid harming the lives of local and indigenous people in our pharmaceutical/supply chains.
*Only deal with established companies/suppliers who demonstrate that they have a CSR policy and that we are not their sole customer
*Support diversity and inclusion.
Our company is dedicated to protecting human rights. We are a committed equal opportunity employer and will abide by all fair labour practices. We’ll ensure that our activities do not directly or indirectly violate human rights in any country (e.g. forced labour).
Our employment contracts and employee handbook demonstrates that we meet legal responsibilities regarding our own employee working hours and rights. We provide fair compensation in line with industry and market norms.
Donations and aid
Our company preserves a budget to make monetary donations to registered charities. These donations will aim to:
Advance healthcare, healthcare education & research and local community events.
Our company will encourage its employees to volunteer. They can volunteer through programs organised internally or externally. Our company may sponsor volunteering events from other organisations. One example of our voluntary services, includes providing foot check-ups and ‘crisis care packs’ to homeless people during winter months. Further details are available on request.
Preserving the environment
Apart from legal obligations, our company will proactively protect the environment. Examples of relevant activities include:
*Recycling – We recycle consumable materials when possible (ie, packaging materials, printer toners, etc). The Clinical Director will oversee this activity.
*Conserving energy – we only have one printer in the clinic and are a ‘paperless’ office, using secure email and cloud technology for all correspondence. In the <1% cases where a hardcopy is required (eg, for certain contracts), we print double-sided as often as practicable.
*Using environmentally-friendly technologies
*We support remote and home-working: this is the way our admin and accounts teams work. At present, only our Clinicians are in the practice (the Clinic building) itself.
*The Directors meet and review our environmental performance at the end of each calendar year
Supporting the community
Our company may initiate and support community investment and educational programs.
We will actively encourage CPD, beyond the levels mandated by professional bodies for registration. We will be open to suggestions and listen carefully to ideas. Our company will try to continuously improve the way it operates.
Our company is committed to being Socially Responsible. We’ll readily act to promote our identity as a socially aware and responsible business.
(3) MODERN DAY SLAVERY
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.
The Company has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. (Modern Slavery Act 2015).
This policy does not form part of any employee’s contract of employment and we may amend it at any time. The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Company has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and implementing reviews to ensure they are effective in countering modern slavery.
You are invited to comment on this policy and suggest ways in which it might be improved.
You must notify a Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
We are committed to ensuring no one suffers any detrimental treatment as a result of reporting their suspicion that modern slavery of whatever form is or may be taking place in any of our pharmaceutical suppliers or other supply chains.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
(4) ANTI-BRIBERY AND CORRUPTION POLICY
We have a zero-tolerance position on bribery and corruption.
We encourage our contractors to recognise and deal with bribery and corruption issues, as well as understand their responsibilities.
We are committed to acting professionally, fairly, and with honesty and integrity in all business dealings and relationships, wherever in the country we operate.
In Motion Clinics will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad. We insist our contractors provide documented evidence of their anti-bribery and corruption policies too.
This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.
In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.
Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision. A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law. Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s directors.
As good practice, gifts given and received should always be disclosed to the clinical director. Gifts from suppliers should always be disclosed. The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the directors should be sought.
We do not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.
We will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.
We accept (and indeed encourage) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agree to disclose all charitable contributions we make. We are careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.
The directors are responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness. Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice. Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager. This policy does not form part of an employee’s contract of employment and we may amend it at any time so to improve its effectiveness at combatting bribery and corruption.
Our Environmental, CSR, MDS and Anti-Bribery policies will be reviewed annually at the end of each calendar year.
Team members are fluent with this policy and can communicate this policy on all levels. Directors/Managers are also responsible for resolving any policy issues.
If our partners are suppliers are found to be non-compliant with our above standards, we will terminate our use of their services.
(Last updated 03/21)