Compliance with the CMA order

On 1st October 2014, the Competition and Markets Authority (CMA) published the Private Healthcare Market Investigation Order 2014 (the Order) as part of the remedies required by its final report on the Private Healthcare Market Investigation.

The Order requires private hospitals to disclose certain information relating to referring clinicians which are set out for The London Clinic below:

“Higher value” services

The London Clinic has consulting suites on either Harley Street or Devonshire Place, which are rented to clinicians on an annual or sessional basis.  Sessional rooms are rented at a cost of £535-£675 per month per session and consulting suites are rented at a cost of £40-£50,000 per annum. The London Clinic considers that this represents a fair market value. A small number of suites are currently rented at rates outside this range and these are in the process of being reviewed.

“Low value” services

The following low value services are also provided to referring clinicians with practising privileges at the hospital:

  • Basic workplace amenities such as tea, coffee, refreshments and stationery
  • Allocated parking on a first-come, first-served basis
  • General marketing support, including online marketing, consultant directories, GP education events
  • Operational and administrative services to facilitate the processing of patient admissions
  • General clinical services such as room space for Multidisciplinary Team meetings.

Corporate hospitality events

The London Clinic has a programme of events for referring consultants, together with an annual Christmas reception. All referring consultants are invited to the Christmas reception which costs approximately £145 per head.

Corporate Hospitality event Date Guests Cost per head
England v Wales rugby 12 March 2016 10 £775
Chelsea Flower Show 24 April 2016 3 plus spouses £500
Aegon Tennis 19 June 2016 4 plus spouses £699
Lords Cricket 16 July 2016 8 £429

Clinician financial interests in The London Clinic

Private hospital operators are required to disclose details of referring clinicians at their facilities who have a share or financial interest in those facilities or any equipment used there. As a charity, we reinvest all surpluses in new technology, facilities and staff development and there is no outside financial interest from consultants.

Clinical advisory services to The London Clinic

Private hospital operators are required to disclose details of certain paid services provided by referring clinicians to private hospitals in addition to exercising practising privileges at that hospital.  The London Clinic pays referring clinicians at a rate consistent with NHS sessional rates (£15,000 per session). Those referring clinicians are specified in the relevant website profiles on The London Clinic website.

 

 

The Modern Slavery Act (2015)

The London Clinic is a standalone independent hospital with registered charity status. Everything we do supports our core purpose as a charity, reinvesting the surplus we make to improve the healthcare provided to our own patients and to the wider community.

Our business practices

At The London Clinic we are proud of our vision to be the most trusted hospital. Our values of being caring, pioneering and inspiring reflect our core beliefs. We developed the vision and values through working with our Trustees, management teams and staff, and these beliefs form the basis of all business decisions and relationships we have.

The London Clinic welcomes the opportunity to increase transparency and report on our efforts to ensure our supply chain remains free of any offences under the Modern Slavery Act 2015.

The London Clinic condemns any form of modern slavery and human trafficking. We operate a zero tolerance policy to any form of slavery. We are committed to maintaining and enforcing robust and effective systems and controls to prevent slavery within our organisation. As a charitable hospital, we have a duty of care to report any Modern Slavery concerns and raise staff awareness.

The London Clinic is dedicated to best practice in the procurement of goods and services in all areas. As part of our initiative to identify and mitigate risk, we have written to our suppliers to inform them of our statutory duty and commitment to comply with the Modern Slavery Act. We expect the same from businesses we work with.

We have undertaken an internal audit of procurement to ensure that we maintain best practice and to ensure that our due diligence systems continue to be robust and effective. We will be assessing our supply chain to ensure that business relationships remain ethical, transparent and fair in line with our values.

In addition to these measures, we will be including a modern slavery clause in our standard terms and conditions for goods and services.

Policy

Our policy on Modern Slavery policy is available to all of our employees through our intranet. The policy reflects our commitment to acting ethically and with integrity in all our business relationships. The London Clinic’s Modern Slavery policy reminds staff of our culture of ‘speaking out’ should they have concerns in line with our ‘Raising a Concern at Work’ policy.

All employees are encouraged to report any potential breaches of our policy and we have safeguards in place for those who do so.