Modern Slavery Act Statement
Introduction
This policy applies to all our operating brands and trading companies including Totally, Totally Urgent Care (Vocare Limited and Greenbrook Healthcare Limited), Totally Elective Care (About Health, Pioneer Healthcare Limited, Totally Healthcare, Premier Physical Healthcare) and Energy Fitness Professionals Limited.
This statement applies to all workers which includes all employees, officers, consultants, contractors, volunteers, interns, casual and agency workers working and all suppliers for Totally or its subsidiaries.
This statement relates to actions and activities during the financial year ending 31st March 2025 and is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the ‘Act’).
Totally is committed to improving its practices to combat modern slavery and human trafficking. This statement sets out Totally’s actions to understand all potential modern slavery risks related to its business and to ensure that there is no slavery or human trafficking in its businesses or supply chains. Totally will strive to improve its practices and to ensure that those we work with, including our partners, do so as well. Totally, as a national organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
Governance
Totally is committed to conducting business ethically and responsibly and fully support the aims of the Act and associated standards. We are committed to tackling slavery and human trafficking wherever we can.
The Board will review and oversee implementation of the modern slavery statement. It sets the approach for Totally approach for modern slavery compliance by our staff across the business functions. The Executive Team manages the composition and publication of our annual statement and provide updates to staff as well as the Board.
Our commitment
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Totally is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. We acknowledge the role that we can play to help to bring this about.
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We are an equal opportunities employer, fully committed to creating and ensuring an inclusive and respectful working environment for all our staff. We want all our staff to feel confident that they can report concerns without any risk to themselves.
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Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.
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We recognise that, as a purchaser of goods and services, we have the opportunity to influence good practices in the employment of people by other organisations.
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We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
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In addition to publishing our modern slavery statement on our website we will add this to the Home Office modern slavery statement registry.
Here are the steps Totally has taken and continues to take to understand and minimise the potential risk of modern slavery in its business and supply chains.
About Totally
Totally is engaged in addressing the challenges of the UK and Ireland healthcare sector by delivering healthcare and providing a range of innovative healthcare services.
Totally consists of multiple services:
- Urgent Care (including Vocare Limited and Greenbrook Healthcare Limited)
- Elective Care (including Pioneer Healthcare Limited (incorporating Totally Healthcare Limited), Premier Physical Health Limited and About Health Limited)
- Corporate Wellbeing (Energy Fitness Professionals (also known as Energy Fit-Pro))
Totally has internal governance hierarchy structures in place. The Board of Directors of Totally plc are responsible for ensuring the hierarchy of its services meet good corporate governance standards around Clinical, Finance, HR and OD, Corporate, IM&T, Environmental and Social governance.
Totally operate services at multiple operating sites across all regions within the UK and Ireland. Totally also operates numerous contracts with the NHS as well as other public and private sector organisations.
Our supply chains
We procure goods and services from the UK and a limited number of overseas suppliers. Where possible we make full use of approved appropriate Procurement Frameworks.
We build relationships with our suppliers to ensure they understand our values, and comply with our expectation and commitment to protect human rights and the environment. As part of our procurement processes, we require all of our suppliers to comply with our Supplier assessments and the requirements of the Modern Slavery Act and include appropriate contractual obligations within our commercial agreements.
Through our Supplier assessment, we require organisations tendering to work with Totally to confirm that they have fulfilled their statutory requirement to have produced a Modern Slavery Statement if they meet the criteria to do so.
Relevant policies and procedures
We are committed to ensuring there is no modern slavery or trafficking in our business or supply chains, and we require all our suppliers to comply with relevant policies; including our Equal Opportunities Policies and specifically to pay due regard to the health, safety, welfare, and dignity of those with whom they come into contact and supported by our supplier code of conduct.
Our policies which relate to the Modern Slavery Act 2015
The following associated policies are available to all workers through our intranet:
- Code of conduct
- Dignity at Work
- Whistleblowing
- Recruitment and Selection
- Equality, Diversity & Inclusion
- Disciplinary Procedure
- Procurement
- Safeguarding
- Social Value
These policies set out the standards required of our staff and include details of the mechanisms in place which can be used report issues or concerns about Modern Slavery linked to our organisation.
Due diligence and risk assessment
A comprehensive checklist of policies enables Totally to identify risks of modern slavery and trafficking in the business and its supply chain. Our risk assessment is applied to all new suppliers joining the business. Assessment of suppliers’ criticality to Totally is based on what they are supplying and how we are using it. This has been generated referencing the recent NHS resilience framework toolkit.
Depending upon risk, this impacts how we manage them moving forwards.
Totally does not enter into business with any other organisation in the UK and Ireland which knowingly supports or is found to involve slavery, servitude and forced or compulsory labour.
Monitoring our performance
Totally has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the business or its supply chains.
Totally will:
- Monitor the number of inductees who receive training in relation to the requirements of the Act through our own internal training and induction programmes.
- Monitor current suppliers in line with the Act.
- Be responsible for compliance and that these measures have been successfully implemented and reviewed on an annual basis.
Totally has a supplier assurance process in place which enables Totally to evaluate potential suppliers before they enter the supply chain, and the organisation will continue to monitor this. Totally has a 
Procurement Manager to oversee and improve the procurement practices of the organisation.
Training
It is essential that all our staff have an awareness of modern slavery issues. We will provide, on an ongoing basis, information, and training to staff. We will also provide one to one support and guidance to our staff:
- How to identify the signs of slavery and human trafficking.
- What steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.
- What initial steps will be taken if slavery or human trafficking is suspected.
- How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation.
- What external help is available, for example through the Modern Slavery and exploitation website helpline at Modern Slavery Helpline
Approval
This statement has been approved by the Totally plc Board on 27 September 2024. The Board will review and update the statement annually.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.
Signed by: Wendy Lawrence
Name: Wendy Lawrence
Designation: Chief Executive Officer
Date: 27 September 2024
Next review date: September 2025
This policy, along with other policies from Totally, can be downloaded from the Policies and Reports page.