Modern Slavery & Human Trafficking Statement 2026/27
Table of Contents
- Purpose and Commitment
- Our Business and Supply Chain
- What We Do
- Our Supply Chain
- Governance
- Policy Framework
- Risk Assessment
- Due Diligence and Controls
- Supplier Governance
- Umbrella Company Governance
- Outsourced Operational Support
- Recruitment Safeguards
- Supplier Expectations
- Training and Awareness
- Reporting Concerns
- Internal Reporting
- External Reporting
- Response and Remediation
- Effectiveness and KPIs
- Public-Sector Alignment
- Continuous Improvement
- Accessibility
- Approval
Financial Year Covered: 1 April 2025 – 31 March 2026
Last Reviewed: September 2025
Approved By the Board: May 2026
Director Signatory: Jason Kalaja – Operations Director
Publication Date: May 2026
(A link to this Statement is provided on our website homepage in accordance with Section 54 of the Modern Slavery Act 2015.)
Purpose and Commitment
ProMedical Personnel Ltd (“ProMedical”, “we”, “our”, “us”) maintains a zero-tolerance approach to modern slavery, human trafficking, forced or compulsory labour, servitude, exploitation, and all forms of unethical labour practice.
We are committed to operating ethically, transparently, and responsibly across all aspects of our business and supply chain. We recognise that healthcare workforce supply chains can present increased risks of worker exploitation if not properly governed and monitored. We therefore maintain controls designed to protect workers, uphold ethical recruitment standards, and identify and mitigate modern slavery risks.
This Statement is published voluntarily in support of the principles contained within Section 54 of the Modern Slavery Act 2015, despite ProMedical not currently meeting the statutory turnover threshold requiring mandatory publication.
This Statement outlines:
- the steps taken during 2025/26 to prevent modern slavery and human trafficking;
- the inherent risks identified within our operations and supply chains;
- the controls and governance measures implemented to mitigate those risks;
- our training and awareness activities;
- and our ongoing commitment to continuous improvement.
ProMedical has not identified any confirmed incidents of modern slavery or human trafficking within its operations or supply chain during the reporting period.
Our Business and Supply Chain
What We Do
ProMedical is a UK healthcare workforce and clinical services provider operating across public and private sector environments.
Our services include:
- Healthcare Workforce Solutions
- Insourced Clinical Services
- Medico-Legal Services
- Neurodevelopmental Diagnostics
- Event Medical Services
- Workforce Redesign & Consultancy
Our Supply Chain
To support these services, our supply chain includes:
- healthcare professionals and temporary workers;
- direct candidate sourcing channels;
- outsourced operational support services;
- umbrella companies and payroll intermediaries;
- compliance and pre-employment screening providers;
- technology and software providers;
- accommodation and transport arrangements where operationally required;
- specialist subcontractors and service providers;
- and standard SME operational suppliers.
We recognise that some supplier categories carry higher inherent modern slavery risks, particularly:
- labour intermediaries and umbrella companies;
- outsourced operational support services;
- lower-paid or high-turnover labour environments;
- accommodation and transport arrangements linked to assignments;
- and subcontracted labour supply models.
Our governance, due diligence, onboarding, monitoring, and contractual controls are designed accordingly.
Governance
Modern slavery governance forms part of ProMedical’s wider compliance, safeguarding, workforce governance, and ethical recruitment framework.
Oversight Structure
Strategic Accountability: Board of Directors
Operational Oversight: Operations Director
Day-to-Day Governance Ownership
Compliance, Quality & Governance Manager
The Board receives oversight information relating to:
- identified risks;
- supplier governance;
- policy reviews;
- training activities;
- escalations;
- and continuous improvement actions.
We align our approach with:
- Modern Slavery Act 2015 principles;
- NHS and public-sector procurement expectations;
- recruitment-sector best practice;
- REC standards;
- ethical recruitment principles;
- and wider labour protection standards.
Policy Framework
Supporting governance documentation includes:
- Modern Slavery Act Policy
- Supplier Code of Conduct
- Whistleblowing / Speak Up Policy
- Complaints Policy
- Equality & Diversity Policy
- Safeguarding Policies
- Recruitment & Compliance Procedures
- Right-to-Work & Identity Verification Procedures
- Worker Onboarding Documentation
- Modern Slavery Awareness Training Handbook
We prohibit:
- worker-paid recruitment fees for obtaining work;
- forced or compulsory labour;
- unlawful deductions;
- document retention;
- exploitative labour practices;
- and coercive financial arrangements.
We require:
- lawful and transparent pay arrangements;
- fair treatment of workers;
- transparent contractual arrangements;
- and ethical recruitment practices throughout our operations and supply chain.
Risk Assessment
ProMedical conducts ongoing assessment of modern slavery and labour exploitation risks across its operations and supply chain.
Areas identified as carrying higher inherent risk include:
- umbrella companies and labour intermediaries;
- outsourced operational support arrangements;
- accommodation or transport linked to assignments;
- lower-paid or high-turnover labour environments;
- and selected indirect procurement categories.
We monitor for indicators including:
- unusual or unexplained deductions;
- worker dependency concerns;
- debt bondage indicators;
- shared bank accounts or addresses;
- document retention concerns;
- coercive behaviour;
- non-transparent payment arrangements;
- and safeguarding concerns.
Risks identified are reviewed alongside mitigation controls and governance actions.
Due Diligence and Controls
Supplier Governance
All relevant suppliers and labour intermediaries are subject to onboarding and governance controls appropriate to their risk profile.
These may include:
- contractual obligations;
- supplier due diligence;
- policy expectations;
- compliance verification;
- certification reviews;
- insurance checks;
- operational discussions and reviews;
- and ongoing monitoring.
Umbrella Company Governance
ProMedical recognises umbrella companies as a higher inherent risk area within the labour supply chain due to the potential for worker exploitation through non-transparent payroll practices or unlawful deductions.
To mitigate these risks:
- ProMedical operates a strict Preferred Supplier List (PSL);
- only approved umbrella companies are permitted;
- umbrella governance is actively monitored;
- and SafeRec assurance processes are utilised to support payroll transparency and compliance oversight.
SafeRec monitoring supports visibility around:
- unlawful deductions;
- non-transparent payroll arrangements;
- disguised remuneration concerns;
- holiday pay irregularities;
- and related worker exploitation risks.
Outsourced Operational Support
ProMedical utilises outsourced operational support services in areas including:
- recruitment support;
- payroll administration;
- compliance administration;
- booking support;
- credit control;
- and operational support functions.
We recognise offshore outsourcing as a higher inherent risk category due to jurisdictional and labour oversight considerations.
To mitigate these risks, ProMedical:
- works with established outsourcing partners;
- maintains direct operational relationships;
- conducts regular Teams meetings and operational engagement;
- undertakes in-person visits where appropriate;
- distributes policies and governance expectations;
- and maintains direct communication with operational staff.
Recruitment Safeguards
ProMedical maintains controls including:
- right-to-work verification;
- identity checks;
- transparent onboarding;
- lawful payment practices;
- and worker acknowledgement processes.
Workers are not charged recruitment fees in exchange for obtaining work.
Supplier Expectations
Suppliers, contractors, intermediaries, and business partners are expected to:
- comply with applicable labour laws;
- uphold anti-slavery principles;
- maintain ethical labour standards;
- prohibit worker-paid recruitment fees;
- cooperate with governance reviews;
- support worker welfare;
- and report concerns promptly.
These expectations are reinforced through:
- contractual terms;
- Supplier Code of Conduct requirements;
- onboarding processes;
- and ongoing supplier engagement.
Training and Awareness
ProMedical provides Modern Slavery awareness training to:
- employees;
- directors;
- managers;
- and outsourced operational support staff.
Training is delivered through:
- HR system distribution;
- mandatory acknowledgements;
- onboarding processes;
- email distribution where appropriate;
- Teams-based sessions;
- in-person discussions and training;
- and refresher awareness updates.
Training content includes:
- Modern Slavery awareness;
- ethical recruitment principles;
- labour exploitation indicators;
- the ILO’s 11 indicators of forced labour;
- umbrella company and payroll risks;
- debt bondage awareness;
- worker safeguarding;
- and escalation procedures.
Targeted operational awareness is provided to teams working in higher-risk operational areas including recruitment, compliance, payroll, onboarding, and workforce operations.
Workers also receive onboarding-based awareness information and reporting guidance.
Reporting Concerns
ProMedical promotes a culture where concerns can be raised safely and without fear of retaliation.
Concerns relating to:
- exploitation;
- safeguarding;
- unethical behaviour;
- labour abuse;
- coercion;
- or suspicious practices
should be reported immediately.
Internal Reporting
Concerns may be raised through:
- line management;
- governance personnel;
- or directly via:
No worker will suffer retaliation for raising genuine concerns in good faith.
External Reporting
Concerns may additionally be raised externally through:
- Police;
- Gangmasters and Labour Abuse Authority (GLAA);
- Modern Slavery & Exploitation Helpline;
- NHS Freedom to Speak Up routes where applicable;
- safeguarding authorities;
- or relevant regulatory bodies.
Response and Remediation
Where concerns are identified, ProMedical prioritises:
- the safety and welfare of affected individuals;
- appropriate safeguarding;
- and prompt escalation where required.
Potential concerns are reviewed appropriately and may involve:
- internal investigation;
- supplier engagement;
- corrective action requirements;
- safeguarding escalation;
- or external authority involvement where appropriate.
Where supplier breaches are identified:
- corrective actions may be required;
- relationships may be reviewed;
- and serious or persistent breaches may result in termination of the business relationship.
Effectiveness and KPIs
ProMedical monitors the effectiveness of its approach through governance oversight and operational review.
Key focus areas include:
- training completion rates;
- supplier governance activity;
- onboarding compliance;
- safeguarding and escalation trends;
- supplier remediation activity;
- and policy review completion.
No confirmed incidents of modern slavery or human trafficking were identified during the reporting period.
Public-Sector Alignment
ProMedical supports the principles of ethical public-sector procurement and aligns its approach to relevant NHS and government procurement expectations where applicable.
This includes engagement with:
- Modern Slavery Assessment Tool (MSAT);
- public-sector supplier expectations;
- and wider ethical workforce governance principles.
Continuous Improvement
During the reporting period, ProMedical continued strengthening its governance framework through:
- enhanced supplier governance;
- implementation of formal Modern Slavery training;
- strengthened umbrella company oversight;
- SafeRec governance integration;
- onboarding-based worker awareness;
- updated policy framework;
- and enhanced public policy accessibility.
Future improvement priorities include:
- continued supplier engagement;
- ongoing training refreshers;
- governance review;
- and continuous enhancement of worker safeguarding and ethical recruitment controls.
Accessibility
This Statement is written in plain English and can be made available in alternative formats upon request.
Approval
This Statement for 2026/27 was approved by the Board of Directors and signed by:
Jason D Kalaja
Operations Director
ProMedical Personnel Ltd
T: 01277 583 850
E: complaints@promedical.co.uk
W: www.promedical.co.uk