Tooting Med Centre trading as SW11 Medical and SW11&Fora Consortium – called SW11 Medical
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our disclosure under the Act. It sets out the steps taken by SW11 Medical Centre Limited Consortium Partners as consortium partners to ensure that modern slavery and human trafficking are not present in our operations, supply chains, or any part of our business. SW11 and Partners are committed to ethical practices in healthcare delivery and recruitment services, particularly in the NHS and private sector.
- Introduction and Company Overview
SW11 Medical is a UK-based GP service provider specializing in family-oriented care, home visits, and specialist consultations e.g., gastroenterology in South West London, with an annual turnover of approximately 20 mln GBP. As consortium partners for the RM6380 NHS Workforce Alliance Health Workforce Solutions framework, we provide integrated services including staff banks, direct engagement, and permanent recruitment, serving the NHS and public sector.Our combined operations involve providing medical and dental services, selling medical equipment , direct employment, agency supply chains, and international sourcing (from EU/Asia for nurses/doctors). We have zero tolerance for modern slavery, human trafficking, forced labor, or child labor in our business or supply chains.
- Structure and Operations
SW11 operates clinics and home services in South West London, employing ~7 staff and engaging subcontractors for specialist roles ( endoscopy training). Our global footprint includes partnerships in India, Philippines, and EU countries for healthcare talent. Risks are higher in international recruitment and subcontractor chains
We conduct ~500 placements yearly, with 30% international, focusing on ethical sourcing to support NHS staffing (e.g., endoscopy nurses at £400/day + markup).
- Policies Relating to Modern Slavery
- Modern Slavery Policy: We have a comprehensive policy (available on our website) prohibiting all forms of modern slavery. It applies to all employees, suppliers, and partners, with annual reviews.
- Human Rights and Ethical Recruitment Policy: Mandates fair wages, no forced labor, and compliance with ILO conventions. For international hires, we ensure no recruitment fees are charged to workers (employer-paid model).
- Supplier Code of Conduct: Requires suppliers (e.g., international agencies) to adhere to anti-slavery standards, with audits for high-risk partners (e.g., those sourcing endoscopy nurses).
- Whistleblowing Policy: Encourages reporting of concerns via anonymous email with protections under the Public Interest Disclosure Act 1998.
These policies are integrated into contracts and communicated during onboarding.
- Due Diligence Processes in Relation to Modern Slavery
We perform due diligence on all suppliers, prioritizing high-risk areas like international recruitment:
- Risk Assessment: Annual mapping of supply chains (e.g., 80% risk in overseas agencies for forced labor). Tools like the Ethical Trading Initiative assess vulnerabilities (e.g., migrant workers in nursing roles).
- Audits and Monitoring: Audits for 20% of suppliers, focusing on recruitment fees and working conditions.
- Contract Clauses: All agreements include anti-slavery warranties, termination rights for breaches, and right-to-work checks for locum consultants/nurses.
- Integration with Tender: For RM6380, we commit to PPN 009 compliance, screening subcontractors for modern slavery risks in staffing supply chains.
In FY 2024-25, we audited 2 high-risk suppliers, identifying no issues.
- Principal Risks and Effectiveness of Mitigation
Risks:
- International recruitment ( exploitation in sourcing endoscopy nurses from Asia).
- Subcontractor agencies for locum consultants potentially using forced labor.
- Vulnerable workers in social care staffing.
Mitigation and Effectiveness:
- Training: 100% of staff (including recruiters) complete annual modern slavery e-learning In 2025, with 95% completion rate.
- Supply Chain Mapping: Full visibility via supplier questionnaires.
- Metrics: Zero reported incidents in FY 2024-25; 100% supplier compliance score. Effectiveness measured via internal audits (quarterly) Improvements: Enhanced due diligence for new Asian partners.
- Remediation: If risks identified, we suspend suppliers and support affected workers
Our measures reduced identified risks by 20% from FY 2023-24.
- Training and Awareness
All employees receive mandatory training on modern slavery (2-hour module covering signs, reporting). Recruiters including subcontractors get specialized sessions on ethical international hiring. In 2025, we delivered training staff, with follow-up quizzes (95% pass rate). Awareness campaigns include website banners and newsletters.
- Approval
This statement was approved by the Board of Directors on 01/09/2025