Modern Slavery Act Policy

Our Commitment

ProMedical Personnel Ltd (“ProMedical”, “we”, “our”, “us”) has a zero-tolerance approach to modern slavery, human trafficking, forced or compulsory labour, servitude, and all forms of exploitation.

We are committed to acting ethically and with integrity in all business dealings and relationships, and to implementing and enforcing effective systems to ensure modern slavery is not taking place anywhere in our business or supply chains. Our approach is values-led and survivor-centred, placing the safety, dignity, and rights of workers at the heart of our actions. 

Scope

This policy applies to: 

  • All persons working for or on behalf of ProMedical – including employees, workers, contractors, consultants, and suppliers. 
  • All aspects of our operations – including recruitment, employment, procurement, and service delivery, whether direct or via intermediaries (e.g., umbrella companies, payroll providers). 

Legal Framework

This policy is made in accordance with: 

  • Related human rights and labour laws in the UK and internationally.
    It complements our other policies, including our Whistleblowing Policy, Supplier Code of Conduct, Recruitment/HR Policies, and Safeguarding Policy. 

Our Approach

We will: 

  • Conduct risk-based due diligence on all new suppliers and contractors, focusing on high-risk areas (e.g., labour intermediaries, worker accommodation or transport). 
  • Require suppliers to confirm compliance with the Modern Slavery Act and to operate ethical, legal working practices. 
  • Include anti-slavery and anti-trafficking provisions in relevant contracts, including our right to audit where concerns arise. 
  • Act promptly if any concerns or allegations of modern slavery are identified, prioritising victim safety and remediation over contract termination where appropriate. 

Responsibilities

Management: 
  • Ensure all staff understand the risks of modern slavery and the measures in place to prevent it. 
  • Oversee supplier due diligence and audits where appropriate. 
  • Review progress against key performance indicators annually. 
All staff: 
  • Report any concerns related to modern slavery in our business or supply chain. 
  • Cooperate with investigations into suspected breaches of this policy. 

Training

We provide training to relevant staff on: 

  • Recognising the signs and indicators of modern slavery and human trafficking, including the ILO’s 11 indicators of forced labour. 
  • How to escalate and report concerns through internal and external channels.
    Training is mandatory for key roles (e.g., recruiters, compliance staff, payroll) and refreshed at least every two years. 

Reporting Concerns

If you believe or suspect that modern slavery is occurring, report it immediately to your line manager or the Governance Lead.

You may also raise concerns under our Whistleblowing Policy via our confidential Speak Up channel (speakout@promedical.co.uk).

External reporting can be made to the Modern Slavery & Exploitation Helpline on 0800 0121 700 or via www.modernslaveryhelpline.org.

Workers in our suppliers’ operations may also raise concerns directly with ProMedical through these channels. 

Continuous Improvement

We regularly review and strengthen our policies, procedures, and supplier engagement processes to minimise the risk of modern slavery.

This policy is reviewed at least annually, to ensure its ongoing relevance and compliance with current legislation, regulatory requirements, and organisational standards. Interim reviews may be undertaken if significant legislative, regulatory, or operational changes occur, with the next review scheduled for 04 September 2026. 

 

Last reviewed: 04/09/2025