This document sets out the commitment of Hero Doctor Limited (company number 10924177), trading as Hero Health (“the Company”, “we”, “us”, “our”), to ensuring that modern slavery and human trafficking have no place in our business or our supply chains. It describes the policies, due diligence and controls we have in place, the areas in which we consider the risk of modern slavery to arise, and the steps we take to assess and manage that risk.
Hero Doctor Limited is not a “relevant commercial organisation” required to publish an annual statement under Section 54 of the Modern Slavery Act 2015, as its total annual turnover is below the £36 million threshold. We have nonetheless chosen to adopt this policy and publish this statement as a matter of good practice and to provide assurance to our customers, partners and contracting authorities.
This policy applies to all individuals working for or on behalf of the Company in any capacity, including employees at all levels, directors, officers, contractors (whether engaged directly or through a third party), consultants and any other third parties acting for or on our behalf. It also informs the standards we expect of the organisations within our supply chain.
Modern slavery is a crime and a violation of fundamental human rights. It takes a number of forms, including slavery, servitude, forced or compulsory labour and human trafficking, all of which involve one person depriving another of their liberty in order to exploit them for personal or commercial gain.
The Company has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically, with integrity and with transparency in all of our business dealings and relationships, and to implementing and maintaining effective systems and controls to seek to ensure that modern slavery is not taking place anywhere in our own business or in our supply chains.
Hero Doctor Limited is a United Kingdom technology company providing software to NHS primary care organisations. Our products support patient communications, online booking, and clinical triage, and are used by general practices and primary care organisations across England, serving over 400 NHS GP practices/PCNs as well as a range of other primary care related organisations (private GP clinics, clinical insourcing organisations).
Our workforce is predominantly United Kingdom-based and professionally employed. In addition, we engage a small number of software contractors based outside the United Kingdom, including in Pakistan, each on a direct contractual basis.
Our supply chain consists principally of large, well-established technology and professional-services organisations, including software, cloud-hosting and infrastructure providers, based in the United Kingdom and the wider European Economic Area. We also use third-party software components within our products — for example, video-consultation functionality provided by an established software-as-a-service supplier — which we license as a customer rather than engaging as a sub-contractor to deliver services on our behalf.
The following policies and practices reflect our commitment to acting ethically and with integrity, and to identifying and mitigating the risk of modern slavery in our operations and supply chains:
Our due diligence is proportionate to the size of the Company and the modern-slavery risk profile of our operations and supply chain:
We have considered where, within our business and supply chains, the risk of modern slavery and human trafficking is most likely to arise.
Highest relative risk — our contractors in Pakistan. We assess our engagement of contractors based in Pakistan as the area of our operations carrying the greatest modern-slavery risk, reflecting that Pakistan is a higher-risk jurisdiction. We do not engage this labour through a third-party agency: we maintain a direct relationship with the individuals concerned, engage them on formal written terms, and pay for their work in full and on time. We hold regular, individual and confidential check-ins with each contractor, giving them a route to raise any concern about pay, treatment or conditions independently of any other party, and we keep the arrangement under regular review. Taken together, these measures give us a high degree of direct visibility over the welfare of those concerned.
Lower risk — remainder of our workforce. The remainder of our workforce is based in the United Kingdom, and our other overseas contractors are engaged in lower-risk jurisdictions on transparent terms, which we assess as comparatively low risk.
Lower risk — supply chain. Our supply chain comprises predominantly large, established technology and service providers in the United Kingdom and wider EEA, which we assess as comparatively low risk, while recognising that risk is never wholly absent and that suppliers may themselves rely on more extended supply chains.
Proportionate to our size and risk profile, we monitor the effectiveness of our approach against the following indicators:
We treat the continued absence of substantiated concerns, together with the maintenance of these controls, as our principal indicators at this stage, and we will keep our measures under review and develop them further as the business grows.
We provide modern-slavery and human-trafficking awareness training to staff as part of our onboarding process, to help them understand what modern slavery is, recognise potential indicators, and know how to raise a concern.
Anyone working for or with the Company who suspects that modern slavery or human trafficking may be taking place — whether within our business, our contractor arrangements, or our wider supply chain — should raise the matter promptly. Concerns can be raised with Augustus Kennedy (CEO) and may be raised in confidence through our whistleblowing / speak-up route. No one who raises a genuine concern in good faith will suffer any detrimental treatment as a result of doing so. Where there is an immediate risk to a person’s safety, the police should be contacted without delay.
Overall responsibility for this policy and statement, and for ensuring that the Company meets its legal and ethical obligations in relation to modern slavery, rests with the Company’s senior management. Managers are responsible for ensuring that those they work with understand and comply with this policy.
This policy and statement has been reviewed and signed off by our Safeguarding Lead and will be reviewed at least annually, or sooner where required.
