Modern Slavery & Human Trafficking Policy

Effective: May 2026  /  Modern Slavery Act 2015/ Section 54 Transparency Statement

1st Healthcare Group Limited has a zero-tolerance approach to modern slavery and human trafficking in all its forms. We are committed to acting ethically and with integrity in all our business dealings and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place in our organisation or supply chains.

1. Our Commitment

1st Healthcare Group Limited is committed to:

  • Conducting our business in a manner that respects human rights

  • Preventing modern slavery and human trafficking in our operations and supply chains

  • Supporting and protecting the welfare of all workers, particularly vulnerable individuals in our care

  • Complying fully with the Modern Slavery Act 2015

  • Transparency in reporting on our anti-slavery efforts

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms including slavery, servitude, forced and compulsory labour, and human trafficking. All are illegal and cause severe harm to victims.

 

2. Our Business and Supply Chains

1st Healthcare Group Limited operates in the healthcare and social care sector in the United Kingdom. As a healthcare provider, we recognise that our sector can present risks of labour exploitation, including:

  • Exploitation of migrant workers in care roles

  • Debt bondage linked to visa or recruitment fees

  • Workers housed in poor conditions by third-party recruiters

  • Workers having passports or identity documents withheld

  • Exploitation of vulnerable service users

We take these risks seriously and actively work to identify and address them in our operations and procurement.

 

3. Our Policies and Due Diligence

We implement the following measures to prevent modern slavery:

1. Robust Recruitment Practices

We conduct thorough right-to-work checks on all employees. We do not use recruitment agencies that charge workers fees. We verify workers' eligibility to work in the UK and pay at least the National Living Wage to all workers.

2. DBS and Background Checks

All staff working with vulnerable adults and children undergo enhanced DBS checks before starting work. We maintain a register of cleared staff and ensure no unchecked individual works unsupervised.

3. Supply Chain Scrutiny

We assess suppliers and subcontractors against our ethical standards before engagement. We require key suppliers to confirm their compliance with the Modern Slavery Act 2015 and our ethical standards.

4. Staff Training & Awareness

All staff receive training on identifying the signs of modern slavery and human trafficking, how to report concerns, and their duty to report. This includes recognising signs in service users and in colleagues.

5. Safeguarding Integration

Our safeguarding procedures explicitly cover modern slavery indicators in relation to service users. We work with local authorities, the police, and the National Referral Mechanism (NRM) where exploitation is suspected.

 

4. Signs of Modern Slavery - What to Look For

Staff are trained to identify the following indicators:

Category

Possible Indicators

Physical

Signs of physical abuse, malnourishment, poor hygiene, inappropriate clothing for conditions

Behavioural

Fearful, anxious, submissive, avoids eye contact, scripted or inconsistent stories

Accommodation

Multiple people living in cramped or unsuitable conditions, controlled by someone else

Work

Working excessively long hours, no control over earnings, debt to employer

Documents

No access to own identity documents, documents held by third party

5. How to Report a Concern

Any person who suspects modern slavery or human trafficking should:

  • In an emergency: Call 999 immediately

  • Modern Slavery Helpline: Call 08000 121 700 (24 hours, free, confidential)

  • Internally: Report to your line manager or Director immediately

  • Anonymously: Via the Modern Slavery Helpline or Crimestoppers on 0800 555 111

 

We will not penalise any member of staff who raises a genuine concern about modern slavery in good faith. Whistleblowing protections apply fully. All reports will be treated confidentially and investigated promptly.

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