Front Entrance to St. Joseph's Hospital

Legal Notices

CMA Compliance

Relationship with our Consultants

The Consultants who treat patients at St Joseph’s Hospital do so having been granted Practicing Privileges and they practice their specialities in accordance with the hospital’s terms.

None of the consultants are employed by St Joseph’s Hospital since they are self-employed practitioners.

The Competition and Markets Authority (CMA) recently issued an Order regulating the relationships between private hospitals and consultants who treat private patients or refer them for tests at the hospitals facilities (so-called “Referring Clinicians”). In accordance with this Order, hospitals and referring clinicians are prohibited from entering into any incentive schemes that are designed to encourage consultants to refer private patients to, or treat private patients at, the hospitals.

St Joseph’s Hospital does not operate any such schemes with referring clinicians.
In addition, the CMA requires hospital operators to disclose certain information about arrangements they have with referring clinicians. These arrangements include: ownership interests in the operator; the provision of certain “high value” facilities to referring clinicians; the availability of “low value” basic amenities for referring clinicians; and any remuneration for services provided by referring clinicians to the hospital. This information applies specifically to consultants who are not hospital employees and who have the ability to refer privately insured or self-paying patients for treatment or tests at the hospital.

Set out below is information about the arrangements we have with our referring clinicians.

Ownership interests

St Joseph’s Hospital is owned in partnership with a number of its referring clinicians.

Referring clinicians generally hold B & C shares which rank equally with all other shares.

Title First name Surname % ownership
Dr Philip Campbell Click to view
Mr Aled Evans Click to view
Mr Andrew Rogers Click to view
Mr Chris Bates Click to view
Mr Ash Khurana Click to view
Mr Brian Stephenson Click to view
Mr Greg Jones Click to view
Mr Hemang Mehta Click to view
Mr Huw Pullen Click to view
Dr Ishan Gunatunga Click to view
Mr James Cordell-Smith Click to view
Mr Kartik Hariharan Click to view
Mr Mark Lewis Click to view
Mr Michael Thomas Click to view
Dr Patrick Flood-Page Click to view
Mr Phillip Alderman Click to view
Mr Simon Hannaford-Youngs Click to view
Dr Sukhdev Singh Click to view
Mr Vasudev Shanbhag Click to view
Dr Victor Francis Click to view
Mr Wayne Williams Click to view
Mr John Lloyd Click to view

Other remuneration

St Joseph’s does not reimburse in general for services that they provide to the hospital, such as membership of Advisory Boards in the areas of Infection Control and Governance.


Below is a list of the facilities we make available to Referring Clinicians and the rates we charge for their use. 

The following facilities are provided to Referring Clinicians at the rates set out below:

  • Referring Clinicians are able to book Consulting Rooms at a set cost
  • Consultating rooms are available on a first come, first served basis with no prioritisation 
  • Referring Clinicians are supported by nursing staff when they use Consulting Rooms without charge.

Basic amenities

St Joseph’s Hospital provides Referring Clinicians with the following basic amenities:

  • In-house training programmes from time to time to promote clinical and operational safety
  • Patient admission, billing, and related administrative services
  • Refreshments, stationery, and parking are made available to the same extent as to emplyed staff
  • General marketing and promotional activities.

Human Rights and Modern Slavery Policy

St Joseph’s Hospital considers violations of human rights to be appalling crimes. Conduct that exploits workers or denies them the rights and benefits to which they are legally entitled is wholly inconsistent with St Joseph’s Hospital values and policies and will not be tolerated.

St Joseph’s Hospital is committed to operating to the highest ethical standards. This includes ensuring its operations, suppliers, contractors, subcontractors and anyone else in its supply chain, including any recruitment agents or other providers of labour (temporary or otherwise) (collectively “recruitment agents”) share our commitment to human rights and are free from practices associated with human rights violations.

This policy applies to all persons working for St Joseph’s Hospital or on St Joseph’s Hospitals’ behalf, including employees, agency workers, bank workers, volunteers, interns, contractors, and third-party representatives (referred to in this policy as Staff).

St Joseph’s Hospital’ Staff must report any actual or potential breach of the policy whether that breach is by St Joseph’s Hospital or by a third party. The report should be made either to your line manager or to HR. St Joseph’s Hospital shall also operate an effective grievance procedure to ensure that Staff can submit a grievance without suffering any prejudice or retaliation of any kind. 

This policy encompasses the following practices that protect Human Rights of Staff:

  1. Elimination of Forced/Involuntary Labour
  2. Elimination of Child Labour
  3. Humane treatment in the workplace
  4. Workplace equality / elimination of bias
  5. Right to a living wage
  6. Right to reasonable working hours and vacation
  7. Freedom of Association
  8. Safe and healthy work place
  9. Safe and healthy accommodations, if accommodations are provided for employees

Staff shall not be subject to any form of forced or compulsory labour or bonded or involuntary prison labour. They shall have the freedom to terminate their employment at any time without penalty on no more than the notice specified in their employment contract or - if not specified in their employment contract on reasonable notice. Under no circumstances will wage deductions of any kind be used to force Staff to continue to work for St Joseph’s Hospital. No member of St Joseph’s Hospital’ Staff shall be made to work as a disciplinary measure and under no circumstances will Staff who are migrant workers be threatened with denunciation to the authorities to coerce them into taking up or maintaining employment at St Joseph’s Hospital.

1.a. Contracts of Employment: Staff shall be given clear and transparent written terms and conditions of employment, which include wages, any legally permissible deductions, working hours, time off, and other working conditions. The key terms and conditions of employment shall always be agreed before that member of Staff starts work at St Joseph’s Hospital. Contracts must always be in a language that the member of Staff understands and include a contract termination clause.

1.b. Recruitment Fees and Deposits: Under no circumstances shall Staff be charged any fee or other costs in relation to their recruitment to work at St Joseph’s Hospital, whether directly or indirectly. Any recruitment fees shall be paid by St Joseph’s Hospital. Also, Staff shall not be required at any time to lodge deposits or security payments with St Joseph’s Hospital or with any St Joseph’s Hospital recruiting agency. St Joseph’s Hospital shall add appropriate restrictions to its contracts with recruiting agencies (at the time of review or renewal thereof) and take other actions as needed to prevent violations of this provision.

1.c. Loans and Advances: Occasionally, and in limited circumstances, St Joseph’s Hospital at its absolute discretion may make loans to employees (for example, to pay training). Under no circumstances shall Staff be forced to work to pay off a debt owed to St Joseph’s Hospital or to any agency from whom St Joseph’s Hospital sources labour.

1.d. Custody of Personal Documents: St Joseph’s Hospital strictly prohibits the confiscation or withholding of passports or other personal identity or travel documents belonging to Staff. Under no circumstances will the retention of personal identity documents be used to force a member of Staff to continue working directly or indirectly for St Joseph’s Hospital. It is only permissible for St Joseph’s Hospital, or for a St Joseph’s Hospital’ subcontractor of labour, to take custody of a member of Staff’s identity documents if it is at the member of Staff’s request (for example, for the purposes of safe keeping) or to take a copy for administrative purposes, provided always that those documents will be returned immediately to that member of Staff upon their request.

The movement of Staff shall not be unreasonably restricted. Staff shall not be physically restricted or confined to the workspace or to accommodation provided by St Joseph’s Hospital or by any of its subcontractors, nor shall any coercive measures be used to restrict any member of Staff’s freedom of movement. For the avoidance of doubt, any restriction of movement applied for reasons of safety (for example, in circumstances where an employee is working in a war zone) shall not violate this policy.

St Joseph’s Hospital will not employ anyone below the age of 16. St Joseph’s Hospital requires its subcontractors not to use staff below the age of 16 on St Joseph’s Hospital’ related work. If a St Joseph’s Hospital business, or the law of any country in which that person is to be employed, has established an age limit above the age of 16 then that limit will apply. St Joseph’s Hospital will take reasonable steps to satisfy itself of the member of Staff’s age before that person starts work at St Joseph’s Hospital.

St Joseph’s Hospital and any recruitment agency working on behalf of St Joseph’s Hospital (in circumstances where Staff is employed by the recruitment agency) shall treat all employees and members of Staff with dignity and respect. St Joseph’s Hospital’ workplace shall at all times be free of any form of harsh or inhumane treatment. Neither St Joseph’s Hospital nor its recruitment agents (in circumstances where Staff are employed by a recruitment agent) shall practice any inhumane disciplinary measure, including corporal punishment, mental or physical coercion, harassment, intimidation or verbal abuse of Staff. Nor shall they apply sanctions that result in compulsory labour. The use or threat of physical violence, harassment and intimidation against a member of Staff or his or her family or close associate, is strictly prohibited and St Joseph’s Hospital shall ensure that no disciplinary procedure is undertaken except in an appropriate manner, in accordance with the law, and for legitimate business reasons.

Staff will be treated fairly and equally, without discrimination or bias based on nationality or legal status (this also applies to anyone involved in the recruitment process). St Joseph’s Hospital shall not engage in or support, and shall take such steps as reasonably needed to prevent recruitment agencies from engaging in, any discriminatory or biased practices in recruitment, remuneration, access to training, promotion, termination or retirement based on gender (including gender reassignment), marital status, family status, religious belief, disability, age, racial grounds (race, colour, nationality or ethnic origin, including membership of the traveller community), genetic information, veteran status, pregnancy, sexual orientation or any other characteristics protected by applicable law. Country nationals will not be treated more favourably than migrant workers (including, in relation to compensation, benefits and accommodation).

All members of Staff will be paid at least the minimum wage required by applicable laws and shall receive legally mandated benefits. Wages shall be paid directly to their bank accounts without deductions (other than deductions required by law, for example, deductions for income tax, or deductions made with the prior agreement of the parties that are not unusual or unreasonable. Wages shall be paid at regular intervals in accordance with that person’s terms of employment. Neither St Joseph’s Hospital nor any agency through whom St Joseph’s Hospital sources labour will seek control of Staff’s earnings or their bank accounts. Under no circumstances shall wages be deducted as a disciplinary measure.

St Joseph’s Hospital shall comply with applicable laws on working hours and holiday entitlements. Except where applicable laws require or permit otherwise, the Hospital would expect standard working hours not to exceed 48 hours per week and overtime hours not to exceed 12 hours per week. Likewise, St Joseph’s Hospital will observe all periods of rest mandated by applicable law, or the policies of St Joseph’s Hospital.

St Joseph’s Hospital respects Staff rights to freedom of association and shall comply with applicable laws governing the rights of workers to freely associate, to form trade unions or other labour organisations, and/or to collectively petition St Joseph’s Hospital with regard to terms of employment and working conditions. St Joseph’s Hospital will not discipline or retaliate against any Staff member seeking to exercise his or her rights to freedom of association including membership in any trade union or labour organisation or participation in any other legally protected activities. St Joseph’s Hospital will not seek to control, directly or indirectly, any trade union or labour organisation which Staff members seek to create or join. St Joseph’s Hospital shall not require that Staff join any particular trade union or labour organisation except to the extent that such membership is mandated either by applicable law or by collectively bargained labour agreement with such union or labour organisation.

St Joseph’s Hospital will engage in good faith negotiations with any authorized and legally recognized trade union, labour organisation or other representative of Staff as to terms of employment and other working conditions and will take such action as reasonably needed to help assure that recruitment agencies similarly engage in good faith negotiations. St Joseph’s Hospital will not engage in or support any unfair labour practice or other conduct intended to intimidate or coerce any Staff member from engaging in legally protected activities in connection with any collective bargaining or collective labour action.

St Joseph’s Hospital shall provide a safe and healthy workplace environment for Staff and shall take effective steps to prevent potential accidents and injuries to Staff members’ health and wellbeing by minimizing, so far as is reasonably practicable, and in cooperation with all Staff, the causes of hazards inherent in the workplace. All Staff: (i) will receive safety and job specific health and safety instructions during the course of their employment with St Joseph’s Hospital; and (ii) shall have access to clean sanitary facilities and drinking water.

Mandatory residence in employer or recruiter operated residences shall not be a condition of employment. Any accommodation that is provided to Staff shall be safe and shall meet reasonable accommodation standards, which shall include ensuring the number of occupants provides for reasonable privacy and is reasonably safe and sanitary. Such accommodation shall meet all local health, safety and planning laws, other relevant laws, and St Joseph’s Hospital policies.

Review of Procedure

This policy will be reviewed regularly to see if it needs to be updated and to ensure compliance with statutory requirements. Any queries or comments regarding this policy should be addressed to the Executive Directors or the Human Resources Representative.

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