When Health Carousel wanted to eliminate the risk of human trafficking and modern slavery from its healthcare personnel recruiting practice, it partnered with UK-based Slave-Free Alliance to develop best-in-class policies and procedures. The result is an ethical recruiting program that isn’t just finding talent. It’s protecting it.
What is Slave-Free Alliance and how does it help companies like Health Carousel?
Rachel Hartley: We are a social enterprise wholly owned by the global anti-slavery charity Hope for Justice, which has been around in the U.S. and the UK for almost 15 years now, doing brilliant anti-slavery work to rescue victims trapped in quite horrific situations.
We had a turning point as a charity about five years ago, where more and more businesses were contacting the charity about these types of issues. They didn’t know what to look for or how to deal with the problems they were coming across. That led us to set up Anti-Slavery Alliance as the business arm of the charity. We offer consultancy services, learning solutions, and a membership program for businesses to partner with us. We donate our business profits straight back into Hope for Justice.
Our sole purpose is to partner with businesses to understand and mitigate their risks of modern slavery and labor exploitation. Should the worst happen, and we find potential victims, we are there to guide our clients through the remediation and what role that they should play in it. We work with more than 100 businesses now across many industries, and we’re expanding globally.
Nothing we do is off the shelf. We’re very intentional with every business we partner with. We’re going to get to know you. We’re going to feel like we’re part of your team and we’re going to do this for the long term together. If that’s something that you’re up for, we are here to help, no preparation needed.
Healthcare Carousel was our first contract with a business in the U.S., and we were really excited to partner with them. It’s been a wonderful partnership so far.
How did Health Carousel partner with Slave-Free Alliance? What problem were you solving for, and how has that effort gone so far?
Andrew Lingo: We started as a company in 2004 and began growing very rapidly after that. A big part of our business is the recruitment of international healthcare professionals for opportunities in the United States. With that comes a great responsibility to work with those individuals and their families responsibly and ethically, because they are picking up their whole life and coming to the United States.
As you grow as a company, the risks that you are exposed to tend to grow as well. We are not manufacturing widgets; we are dealing with people moving around the world in a contract employment relationship. And we are dealing with agents that are representing our company to recruit. This year, we are hoping to have a thousand new starts on assignment in the United States—that means getting everyone here, getting them proper housing, making sure they understand their contracts fully, and on and on. So we felt we needed a partner to help us understand where those risks were, how to do the best we can going forward, and to help us examine some of the issues that we had at the time.
When I was trying to find a company that could provide the support that Slave-Free Alliance provides, I have to admit, there was some selling internally that SFA exists as a partner for improvement and change, and not as a critic. If you invite someone to look behind the scenes and you openly discuss your issues and where you want to go, you don’t want them to take that information when you’re trying to improve and then throw it in your face. The conversations that we had with Rachel and other SFA team members really gave us certainty that they were a partner towards improvement.
Why is it important for companies like Health Carousel to partner with organizations like Slave- Free Alliance rather than trying to address ethical recruitment issues entirely on their own?
RH: This is a real leadership move from Health Carousel, I feel. The healthcare industry is quite complex and nuanced in its risks, so it’s important to get that partner. But it’s not just the healthcare industry. Any company in any industry can’t do it on their own. We all need specialists and experts in various different fields for the work that we do. And it’s important to get that independent perspective as well and to sense check that you are heading in the right direction.
I would love to see more of this in the healthcare industry, where there are so many different kinds of companies playing so many different roles. Recruitment is a really interesting one. We know that recruitment, generally, is high-risk for issues around modern slavery and labor exploitation across many industries. So the more we have businesses involved in recruitment that are stepping up to the plate, the more we can raise the global standard of how this is done.
What does an ethical recruitment program look like? And what are some of the specific challenges and opportunities that come with ethical recruitment within your specific healthcare space?
AL: Bill DeVille, our Board chair and one of the founders of the organization, formed the American Association of International Healthcare Recruitment (AAIHR) around 2008, when Health Carousel was in its infancy. It put in place a code of practice not just for staffing agencies and recruitment companies to follow, but for the healthcare professionals themselves. Even when we were just barely getting off the ground, we were saying we need to work with other organizations like ourselves to set some standards. That was the beginning. We also went through audits from the Alliance for Ethical International Healthcare Recruitment (AEIHR), which is a division of the Commission and Graduates of Foreign Nursing Schools (GCFNS). Bill worked with them and has been a board member to create their ethical standards. And those codes are not one time things. They are revised to reflect what needs to be done in the industry.
When we work with recruiting partners and agents, they have to understand our business. They have to understand the Trafficking Victims Protection Act (TVPA) and other global regulations. We have put into place strong staff training so all of our staff understands every one of those laws. And Bill is the champion of this, because people have to fully understand how critical it is that we do this right. So those are several ways that we were already considering these issues even before we began working with Slave-Free Alliance.
Why is the healthcare sector considered high-risk for modern slavery?
RH: The reality is, there are pockets of risk everywhere. No sector is free from it, and we can’t get complacent about it.
The healthcare industry fascinates me because there are very large and different buckets of risk. The first one is the frontline piece. You’ve got the potential exploitation of healthcare professionals themselves, which is why ethical recruitment is so important. But at the same time, you have the potential of patients as victims. A modern slavery victim is likely to visit a healthcare facility at least once during their exploitation because physical violence is such a big part of how this kind of exploitation works. Or, they are placed in unsafe work without the right protective equipment, and they might suffer an injury.
It is very likely that a healthcare professional will come across at least one victim of modern slavery in their career, so it is important that our frontline staff is safe and knows what to look for. There’s a lot of training around that in healthcare because it can be quite similar to victims of domestic abuse. If you think you’re faced with a patient who is a victim of domestic abuse, but their controller is with them, how do you try and get them on their own and give them a space to speak up? Modern slavery has a really similar victim profile in some ways. Inevitably, you might find that a victim is there with a controller. So healthcare staff can spot these kinds of problems.
“It is very likely that a healthcare professional will come across at least one victim
of modern slavery in their career, so it is important that our frontline staff is safe
and knows what to look for.”
The second big area of risk is in the operations of healthcare itself and healthcare facilities. There is quite a reliance across the industry on migrant workers. This is where Health Carousel comes in. They’re recruiting brilliant international healthcare professionals and bringing them to different places. We love having that expertise around the world and different learnings. But ultimately, migrants by default are a vulnerable group when it comes to exploitation. When you do that kind of movement, where you go to a new space where it’s perhaps not your first language and you don’t understand the employment law, you are vulnerable. So we see that big reliance on migrant workers as a red flag for potential exploitation. There’s also a lot of recruitment vendors used in that sense too; we have to make sure they are giving an accurate representation of the job ahead of them, and that they’re not doing anything to put that person at a disadvantage, such as charging them recruitment fees that they shouldn’t be paying.
But then in the actual space of a healthcare facility, we’ve got services that are high-risk. We’ve got retail that’s high-risk. If you imagine yourself walking through a hospital, you’re going to pass cleaners doing the laundry of the beds, maybe a gift shop, or somewhere selling food. All of these spaces contain risk, and all of these servicepeople are also at risk. Cleaners are at high risk for exploitation because of the nature of the work. We see it so often. Again, it’s migrant workers, and a lot of these people might work at night when there’s fewer people around.
Then there’s the supply chains of all of those things as well, which adds another element. And that includes the construction of a functioning healthcare space. The whole operational risk is a really nuanced field.
And then lastly, there’s the procurement of medical goods. Healthcare facilities are getting supplies—consumables, medical equipment, uniforms pharmaceuticals…the works. All of these supply chains are very different, multi-tiered, complex, fragmented, and global.
It’s hard to really understand where your risk is so that you can address it.
So between the frontline, the operations, and the supply chains themselves, we’ve got a lot of risk across this industry. We really need everyone who’s playing their part in the healthcare industry to stand up and get involved in this agenda.
Health Carousel is a member of the Business Ethics Leadership Alliance (BELA), and it’s one of only two BELA members with a focus on healthcare staffing. What have you learned through your partnership with Slave- Free Alliance that you would want to share with your fellow BELA members?
AL: Acts of modern slavery aren’t necessarily limited to non-professional, low-wage earners. If you’ve got a registered nurse who is earning a good wage, they’re still susceptible. There are a number of businesses that are recruiting healthcare professionals from abroad, so they’re all open to that risk. We hear stories from nurses and healthcare professionals that have worked in other countries, and they are shocked that we don’t do certain things, like hold onto their immigration documents. We have to be cognizant that the people that come to us may have already gone through this. It may not have necessarily resulted in violence or them not getting paid, but it definitely led them to their job in a unethical way. We see that pretty much on a weekly basis, especially when our recruiters are talking to these nurses that have worked overseas.
During COVID-19, the global population of modern slaves increased almost 20 percent, to 50 million people. How do we address a system that allows for such an extraordinary increase in slavery?
RH: That increase is shocking, but it isn’t even the full picture of what we’re dealing with. Modern slavery is such a dark, hidden practice. It’s designed not to be found, even when it operates in plain sight. So any data we manage to get, we treat it as a minimum. I think the figure of 50 million modern slaves is just the tip of the iceberg. We’re dealing with something far greater than that.
Without legislation in place globally, we need businesses to step up, act more responsibly, improve their practices, get a handle on their supply chains, and ensure that they are hiring safe workforces that have been recruited legitimately. There are some awful human rights issues around the world, but forced labor is something that we could stamp out with good business practice.
How important is it that Health Carousel reached out to Slave-Free Alliance?
RH: It’s so important and it’s so commendable. I know a lot of businesses are still quite scared to get involved in this agenda. There’s hesitancy around uncovering something that could shatter their reputation. But Health Carousel has shown that we can lean into this in a transparent and open way to accept that we are dealing with risk because of the sector we operate in. We have to accept that. So how do we proactively mitigate these risks? How do we make sure that we’re doing the right thing?
Health Carousel is a brilliant example of a company that stepped into that risk space to take control of it so they wouldn’t fall victim to these awful practices of criminal gangs or do something that has unintended consequences in the way that they work, and to constantly improve and ensure that they are acting as a responsible business.
We love it when this happens. This is what we need from more companies. You will never be ready and there will never be the right time. But if you start with small and meaningful steps, you quickly end up on a good journey.
Andrew, where has your work with Slave-Free Alliance made the biggest difference so far within Health Carousel?
AL: On many occasions, there have been nurses we have recruited that had previously been charged fees to find a job that didn’t live up to expectations, or they’ve had their important immigration and visa documents withheld. They’ve just been in bad situations. By being a more responsible staffing agency and employer, we help them overcome that and get them into a better situation in the United States. That happens on a regular basis.
We also support the whole family. It is very common practice for nurses from around the world to accept jobs in other countries and be separated from their families. They might have young children at home that they leave for two years. They might return home for two to four weeks per year, but other than that, they do not see their families. We encourage and assist with the immigration of the whole family, so that nurse will have a support system when they get to the United States. If they are alone and don’t know anyone, that makes them more vulnerable than if they’ve got their spouse and children with them, and are connected to the school system and their church—which are all things we do for them when they arrive. We have a housing department that finds them safe, clean housing for when they come to the United States.
We do their arrivals in person. We know the clients that they’re going to, and we do site visits. We know the importance of visiting everyone in your supply chain, so we’ve been to all of these facilities when people are being placed. We don’t work with ones that we don’t think are good places to work. I think we’re doing a lot of things that combat modern slavery from slipping into our process and our business by being very hands-on and supporting the family and the community that they live in.
RH: I think Andrew’s drastically underselling himself here. <Laughs.> He makes a difference every day in Health Carousel. The initiatives that Andrew starts, and the business that he supports, is all about empowering the employees to make responsible decisions, act responsibly, and put the care of people first. He is quite a beacon within the organization for that. So, all this brilliant prevention work can’t be overlooked. The more you reduce potential vulnerability, the more stability you offer to someone, the more you reduce the likelihood of something going wrong. That’s where the best work is. Prevention is everything.
AL: Being a member of Slave-Free Alliance is something you have to be accepted into. You just don’t pay your money and say, “I’m a member.” We had to go through an extensive evaluation process to make sure that we were a fit. I’ve sent Rachel a ton of documents over a six-month process of interviews with internal and external constituents, and healthcare professionals that hadn’t yet arrived in the United States but were on their way. It was quite extensive.
After Slave-Free Alliance came back with a list of suggestions and said we could join, Rachel did some in-depth staff training which was really well-received. I think that the staff walked away with the same perception, that we’re doing a lot of the right things, but we can improve on some of them. And there are still suggestions from SFA that I am turning into policies and procedures right now so we can capture data better and spot recurring trends. This is all based on the studies that Rachel and her team did and the feedback they provided us.
You have to trust in an organization like Slave-Free Alliance and let them do an audit of your organization and see where you can improve. Because the end result is that you will be a better organization if you actually act upon what they’re doing. This is a long-term thing. It’s not one and done. It has to be an ongoing commitment.
ABOUT THE EXPERTS
Andrew Lingo is Director, Ethical Recruitment & Workforce Sustainability for Health Carousel.
Rachel Hartley is Consultancy Director, Hope for Justice and Slave-Free Alliance.
