Modern slavery and human trafficking statement

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Modern Slavery Statement

Modern slavery refers to the exploitation of people who have been forced, deceived or coerced into labour and servitude. This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, sets out Ascenti’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at identifying risks of modern slavery or human trafficking in its own business and its supply chains and ensuring that processes are in place to ensure that Ascenti does not engage with either directly or indirectly modern slavery or human trafficking practices in either the United Kingdom or overseas. This statement relates to actions and activities during our financial year between December 2022 and November 2023.

Ascenti is committed to acting ethically and with integrity in all business interactions, and to implementing policies and processes and actively working to ensure fair and equitable practices are in place.

As part of the healthcare sector, Ascenti recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking. Ascenti is absolutely committed to preventing modern slavery and human trafficking in its own activities, and ensuring that those in its supply chains and contractors are reviewed and vetted for compliance with modern slavery legislation, and comply with our values.

Organisational structure and supply chains

This policy covers the activities of bd-c Incline Midco Limited, bd-c Incline Bidco Limited, Ascenti Health Limited, Ascenti Physio Limited, Advo Health Limited, Six Physio Limited and all members of the Ascenti Group.

Ascenti is a provider of rehabilitation services nationwide to insurers, employers, the NHS, personal injury and private patients. Ascenti’s head office is in Fareham but operates nationwide.

The Ascenti Group currently only operates in the United Kingdom and collectively the Ascenti Group has an annual turnover of £42m.

Ascenti’s supply chain mainly comprises physiotherapy and treatment providers instructed to provide physiotherapy, mental health and related services. Our supply chain also comprises suppliers as expected in the running of offices and healthcare and assessment clinics, including facilities services, recruitment agencies, training and equipment providers.

Risk Assessment and Management

Ascenti maintain a risk management framework aimed at identifying and assessing risks which impact on our operations. A risk-based approach is applied to engaging with new suppliers/renewing contracts. This is to ensure both compliance with legislation and alignment with our values.

Ascenti does not believe it is engaged in any activities or is involved with any suppliers in countries which have been identified as being at high risk in relation to modern slavery or human trafficking.

Responsibility

Overall responsibility for Ascenti's anti-slavery initiatives resides with the Executive Team who take a lead in ensuring policies and practices align to our values and ensure the safety and wellbeing of individuals within our direct and indirect control.

Policies in relation to modern slavery and human trafficking

Ascenti operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Code of Conduct: Ascenti has a Code of Conduct published on its website to ensure that suppliers are aware of our expectations and fundamental principles, and that these should extend into their own businesses and supply chain.
  • Whistleblowing policy: Ascenti encourages all its staff, clients and other business partners to report any concerns related to the direct activities or supply chains of Ascenti. This includes any circumstances that may give rise to an enhanced risk of modern slavery or human trafficking. Ascenti's whistleblowing procedure is designed to make it easy for staff to make disclosures without fear of retaliation, and therefore includes an anonymous hotline and online reporting via Safecall.
  • Behaviour at work policy / Equal opportunities policy: Ascenti’s policies make clear to staff the actions and behaviours expected of them when representing Ascenti. Ascenti strives to maintain the highest standards of employee conduct and ethical behaviour ensuring fair and equitable opportunities, including when operating abroad and managing its supply chain.
  • Environmental Management System: It is part of Ascenti’s ongoing commitment to reduce the impact the company has on the environment by checking and monitoring suppliers’ and contractors’ standards through a third-party questionnaire. This process is aimed at ensuring an overall increase in suppliers’ ethical obligations around our environment and our people.
  • Quality Management System: The Quality Policy sets out Ascenti’s commitment to high quality practices, including a collaborative partnership approach to working with our key suppliers. Our quality management system provides a structure to review, investigate and report on all elements of the business, including our suppliers.

Due diligence

Ascenti has committed to undertaking due diligence activities when engaging new suppliers, and regularly reviews its existing suppliers. Ascenti's due diligence and reviews include:

  • Broadly considering suppliers to assess particular product or geographical risks of modern slavery and human trafficking;
  • Checking whether a business has a Modern Slavery and Human Trafficking Statement, and what policies they have in place;
  • Evaluating the modern slavery and human trafficking risks of each new supplier;
  • Taking steps to improve substandard supplier practices, including providing advice to suppliers and requiring them to implement action plans;
  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan, including the termination of the business relationship;
  • Ensuring contractual controls are in place with suppliers in relation to complying with legislation, including Modern Slavery and Human Trafficking.

Training

Ascenti is required to ensure that staff are aware of the requirements surrounding modern slavery and human trafficking and are committed to providing training as necessary to ensure staff are aware of the risks both directly and through our supply chain relationships.

Key performance indicators

In order to assess the effectiveness of our approach to modern slavery, Ascenti will be reviewing the following areas on a regular basis:

  • Staff awareness
  • Reviewing existing supply chains; and
  • Ensuring due diligence for any new supplier