Modern Slavery Act 2015

Modern slavery and human trafficking statement


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. Devon Doctors is committed to improving practices to combat modern slavery and human trafficking.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Devon Doctors’ modern slavery and human trafficking statement for the financial year ending March 2022.

Organisational structure

We are a not for profit Social Enterprise providing commissioned primary, dental and urgent healthcare services to approximately two million patients across the South West including residents, students and holidaymakers.

We currently provide or are responsible for two Integrated Urgent Care Services (IUCS), which includes: NHS 111, Clinical Assessment Services (CAS) and out-of-hours GP services across Devon and Somerset. Other services including the provision of dental advice and urgent treatment services are provided across the South West. This range of specialist advice means that more patients can make one phone call to get the ‘right service, right place, first time’. We are also responsible for primary care GP practices in Plymouth and Exeter. This includes a specialist surgery in Exeter and a PCN in Plymouth. We employ approximately 700 staff and have an annual turnover of just over £36 million.

Our policies on modern slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. In light of the obligation to report on measures to ensure that all parts of our business and supply chain are modern slavery free, we regularly review our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues. Our workplace policies and procedures demonstrate our commitment to acting ethically and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our supply chains.

The organisation has strong policies for safeguarding, whistleblowing and complaints to ensure that where modern slavery is suspected, this can be managed sensitively and appropriately with the correct safeguards in place. To review and understand our suppliers we have incorporated the modern slavery supplier review in to our Environmental Social Governance strategy. This work seeks to ensure that our largest suppliers are reviewed and asked detailed questions relating to their modern slavery processes. Also to ensure that modern slavery clauses are contained in contracts with all suppliers.

All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking with the Finance Department taking responsibility for overall compliance.

Due diligence

To identify and mitigate the risks of modern slavery and human trafficking in our own business and our supply chain we:

  • Where possible, build long standing relationships with reputable suppliers.
  • Protect whistle blowers and encourage staff to report any concerns using our Freedom to Speak Up Guardian.
  • Ensure our staff receive fair pay rates and contractual terms with the support of our Union, HR Department and specialist legal team.
  • Adhere to the National NHS Employment checks / standards. These include checks regarding employees’ UK address, right to work in the UK and obtaining suitable references for both employees and agency staff.
  • Staff are trained to recognise, monitor and report any concerns regarding human trafficking and modern slavery.

We are aware of the responsibilities we have towards our service users and the public and encourage staff to report any concerns. Our Vulnerable Adults and Safeguarding Children policies have been developed in accordance with national and local safeguarding legislation and guidance. They include guidance on recognising and reporting a suspected modern slavery or human trafficking victims and / or incidents. To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, our mandatory induction training (for all staff) includes information on modern slavery and human trafficking awareness.

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains we intend to take additional steps to combat slavery and human trafficking by requesting from all our suppliers who do not have a publicised modern slavery statement, a completed due diligence questionnaire confirming their compliance with modern slavery legislation.

The Modern Slavery Act and its explanatory notes are available at:

The Board of Directors has considered and approved this statement and will continue to support the requirements of the legislation.

Director and Chief Strategy Officer
April 2022