Modern Slavery Act statement
Life UK Holdco Limited (“LUH”), Life UK Healthcare Limited (“LUHC”),Alliance Medical Group Limited (“AMG”) and Alliance Medical AcquisitioncoLimited (“AMAL”) are the UK holding companies for a group of companies that operate in several countries including the UK.
LUH, LUHC, AMG and AMAL do not trade themselves; the business in the UK is operated through its subsidiary companies set out below:
- Alliance Medical Limited (“AML”),
- Alliance Medical Radiopharmacy Limited (“AMRL”)
- Alliance Medical Leasing Limited (“AMLL”)
- Alliance Medical Holdings Limited (“AMHL”)
- Alliance Diagnostic Services Limited (“ADSL”)
- Alliance Medical Diagnostic Imaging (Northern Ireland) Limited (“AMDI”)
- European Scanning Centre (Harley Street) Limited (“ESC”)
- Life Molecular Imaging Limited (“LMI”) (“the Group”) and
- Lodestone Patient Care Limited (“LPC”).
(“LUH, LUHC, AMG, AMAL, AML, AMRL ,AMLL, AMHL, ADSL, AMDI,ESC, LMI and LPC” together being referred to as the UK Entities”).
UK Business Overview
AML is a provider of complex diagnostic imaging services, and these services have been provided for more than 30 years either through itself or its other trading subsidiaries ADSL, AMDI, ESC, AMRL and LMI. AMDI is a provider of complex diagnostic imaging services in Northern Ireland working in conjunction with the Alliance Medical diagnostic imaging business in Ireland.ESC is also a provider of complex diagnostic imaging services which utilises innovative and advanced scanning equipment. AMRL manufactures and distributes radiopharmaceutical products which are used in conjunction with the diagnostic imaging services. LMI is engaged inter-alia in the research, development and commercialization of various F-18 labelled radiopharmaceuticals and owns, co-owns and/or has licensed the respective intellectual property. LMI operates either via 3rd party contract manufacturers or licensees in the manufacture of products and supplies internationally either directly or through cooperation partners. It also engages in medical research activities working in conjunction with other parties. AMLL purchases scanning equipment that is used by AML at certain sites to provide its diagnostic imaging services and is the principal contracting party for construction and development contracts for certain new sites. The UK Entities work collaboratively with clinicians, public and private healthcare organisations, and academic institutions to provide high quality and cost-effective diagnostic imaging services and radiopharmaceuticals to its customers and for its patients.
The UK Entities’ supply chain includes procurement of scanning equipment and associated information technology equipment, transportation of mobile scanning units and radiopharmaceuticals, agency staff, medical and non-medical consumables, and construction and maintenance of buildings.
The UK Entities are committed to combating the real and growing problem of modern slavery and human trafficking.
Recognising that it can affect any sector or industry, we take seriously our responsibility to be alert to the risks, however small, in our business and in our wider supply chain.
Our expectation is that our people and our suppliers share our commitment to ensuring modern slavery and human trafficking do not exist in our business or supply chains.
The Life Healthcare Group, including all its subsidiaries, has developed a Global Code of Conduct that sets out its commitment to combatting modern slavery and human trafficking.
Employment policies and procedures throughout Life Healthcare are designed to treat all individuals who work within our business with dignity and respect, to reward them fairly for their work and not to exploit them.
Our commitment is to only work with organisations in our supply chains that have a similar commitment and are not involved in modern slavery, or human trafficking and adhere to our values and principles
Whilst it is the obligation of those organisations to operate their own policies and procedures to achieve that objective, we will develop and build upon our existing practices to ensure we take all reasonable steps to verify compliance by all our material suppliers with the provisions of the Act.
Assessment of Risk within our Supply Chain
A high-level assessment of our supply chains and the potential for slavery and human trafficking has been completed. Most of our suppliers are based in the UK, and many are operating in specialised rather than low skilled industries and pose a lower risk in terms of compliance with the Act.
However, we recognise that some of our suppliers operate in sectors that are potentially higher risk and that some services may involve relatively high levels of contracted labour (for example textiles relating to staff uniforms).
We continue to periodically review and re-assess the risks and are committed to procuring goods and services in a manner which recognises the importance of human rights; we expect all our suppliers to honour and observe the same principles.
If there is evidence that a supplier is non- compliant with our policies and contractual requirements, we will take action to address the shortfall, either through a performance improvement plan or, ultimately, through termination of contract.
Actions taken in the last 12 months
- We have taken action to embed the Supplier Code of Conduct within the business ensuring that this is integrated as part of our procurement process.
- Environmental, Social and Governance (“ESG”) training has been provided to senior employees in the UK and an ESG strategy for the business has been developed.
- A review of the Act and its provisions along with any developments has been undertaken with the accountable executive of the business as part of the business’s compliance programme.
- A review of the existing training provided to employees as part of the employee Induction Programme has been undertaken and employee training needs assessed.
Actions to be undertaken in the next 12 months
- To continue to re-assess the risks posed to the business in connection with the Act.
- To review and monitor developments and proposed changes to the Act in accordance with the businesses’ compliance programme.
- To develop and introduce a digitised mandatory training module covering the provisions of the Act for all appropriate employees.
- To develop and deliver a specific training session on the Act to the business’s procurement, finance, and HR teams.
- To continually review the provisions of the Act as applicable to our business activities.
Approval by the Board of Directors
Each of the board of directors of the UK Entities has approved this statement for the financial year ending 30 September 2022
Mark Chapman – Chief Executive Officer - International