Anti-Slavery Policy Statement

Modern Slavery & Human Trafficking Policy (PPN 009/23 Aligned)

Policy Statement

The term slavery is often associated with the 18th and 19th centuries; however, the practice continues today in one form or another in every country in the world and is becoming significantly more prevalent in the UK.

The Modern Slavery Act 2015 consolidates slavery and trafficking offences and introduces tougher penalties and sentencing rules. It ensures that law enforcement agencies have the powers they need to pursue, disrupt and bring to justice those engaged in human trafficking, slavery, servitude and forced or compulsory labour. It also introduces measures to enhance the protection of victims of slavery and trafficking.

MMP provides contract and temporary recruitment service within the healthcare recruitment market in the UK and Cyprus, Gibraltar, Belgium, Germany, Kenya, Falklands, Brunei.

We oppose all forms of slavery and trafficking and are fully committed to compliance with the Modern Slavery Act 2015 and to meeting the enhanced supplier expectations set out in PPN 009/23. We will take proportionate and risk–based steps to prevent, detect and remediate modern slavery in our operations and supply chains.

1. Purpose

This policy sets out MMP’s approach to preventing modern slavery and human trafficking in our business and supply chains. It describes the steps we take to meet the requirements of PPN 009/23 when bidding for and performing UK Government contracts.

2. Scope

This policy applies to:

  • All employees of MMP (permanent, temporary, agency and contract staff).
  • Temporary Workers on a Contract for Services
  • Directors, officers and senior managers.
  • All suppliers, subcontractors, consultants, agents and business partners who provide goods or services to MMP.
  • Any third party acting on our behalf.

All employees are made aware of this policy and their responsibilities as part of induction and ongoing training. Suppliers and partners are made aware of the policy through contractual terms, onboarding and supplier communications.

3. Definitions

Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. It can take many forms including forced labour, bonded labour, child labour, descent–based slavery, and exploitation through coercion, deception or abuse of vulnerability.

PPN 009/23 refers to the Cabinet Office Procurement Policy Note on tackling modern slavery in government supply chains and sets out enhanced due diligence and reporting expectations for suppliers to government.

4. Responsibilities and Governance

  • Board Directors: Responsible for overall oversight and approval of this policy and any Modern Slavery Statement.
  • Lynn Middleton: Responsible for day–to–day implementation, monitoring, supplier due diligence and escalation.
  • Procurement Team: Responsible for supplier onboarding, contract clauses, risk assessments and supplier monitoring.
  • HR: Responsible for recruitment checks, worker welfare, training and remediation where issues are identified.
  • All employees: Must comply with this policy, complete required training and report concerns promptly.

Disciplinary action, up to and including summary dismissal, may be taken against any employee who breaches this policy. Contractors and temporary workers may have assignments terminated for breaches. Suppliers and partners risk contract termination for serious or repeated breaches.

5. What is Modern Slavery

Someone is in slavery if they are forced to work through mental or physical threat; owned or controlled by an employer; dehumanised or treated as property; physically constrained or restricted in freedom of movement.

Common forms include forced labour, bonded labour, human trafficking, descent–based slavery, child slavery, slavery in supply chains and forced or early marriage.

6. Common Signs of Modern Slavery

Common indicators include fearful or anxious behaviour; isolation; lack of control over personal documents or money; poor living conditions; unusual travel patterns; signs of physical abuse; inability to speak for themselves; and other indicators listed in the original policy.

7. Due Diligence and Supplier Management

7.1 Risk-Based Approach: We apply a proportionate, risk–based approach to due diligence that considers sector, geography, labour intensity, subcontracting complexity and supplier profile.

7.2 Supplier Onboarding and Screening

  • All Tier 1 suppliers must complete a modern slavery risk questionnaire during onboarding.
  • Suppliers must confirm compliance with the Modern Slavery Act and provide copies of any Modern Slavery Statements, relevant policies, and evidence of worker protections where requested.
  • For higher–risk suppliers, we require additional evidence: recruitment practices, payroll records, worker contracts, agency arrangements, and details of any subcontracting.

7.3 Contractual Controls

  • Modern slavery and human trafficking clauses will be included in all relevant contracts. Clauses will require suppliers to:
    • Comply with applicable laws and this policy;
    • Permit audits and site visits where risks are identified;
    • Notify MMP of any modern slavery incidents or investigations;
    • Cooperate with remediation and corrective action plans.

7.4 Ongoing Monitoring

  • Suppliers will be monitored through periodic reviews, risk reassessments and, where appropriate, audits.
  • High–risk suppliers will be subject to enhanced monitoring, including documentary evidence, site visits and third–party verification.

7.5 Remediation and Escalation

  • Where modern slavery is suspected or identified, we will take immediate steps to protect victims, investigate, require corrective action, and escalate to senior management and, where required, to external authorities.
  • We will work with suppliers to implement remediation plans; where suppliers fail to remediate, we will consider contract termination and reporting to relevant authorities.

7A. Subcontractors and Supply Chain Compliance

Scope and Application: This section applies to Tier 1 suppliers and must be flowed down to any subcontractors or downstream suppliers engaged by them. All references to “supplier” include subcontractors, labour providers and any third-party delivering goods or services on our behalf.

Mandatory Contractual Obligations

  • Flow down clause — All contracts and subcontracts must include a modern slavery clause requiring compliance with the Modern Slavery Act 2015, PPN 009/23, and this policy. Suppliers must ensure the same obligations are imposed on their subcontractors.
  • Notification obligation — Suppliers must notify MMP immediately if they become aware of any actual, suspected or alleged modern slavery, human trafficking or related labour exploitation in their operations or supply chain. Notification must include incident details, affected workers, immediate remedial actions and proposed next steps.
  • Right to audit and access — MMP (or its appointed auditors) has the right to conduct audits, site visits and worker interviews at supplier premises and at sites of subcontractors where there is reasonable suspicion of non–compliance. Suppliers must cooperate fully and provide access to records, payroll, recruitment documentation and accommodation records where relevant.
  • Remediation and corrective action — Where non–compliance is identified, suppliers must implement an agreed corrective action plan within specified timescales. Failure to remediate satisfactorily may result in suspension of work, contract termination and reporting to relevant authorities.
  • Termination for breach — Serious or repeated breaches of modern slavery obligations by a supplier or its subcontractors may lead to immediate termination of the contract and recovery of costs where appropriate.

Due Diligence and Onboarding for Subcontractors

  • Risk–based screening — All subcontractors must complete a modern slavery risk questionnaire during onboarding. The level of due diligence required will be proportionate to the supplier’s risk profile (sector, geography, labour intensity, use of third–party recruiters, subcontracting depth).
  • Supply chain mapping — High–risk suppliers must provide a map of their supply chain (at least to Tier 2 where practicable), identifying key subcontractors, recruitment agents and labour providers.
  • Documentary evidence — Suppliers must provide, on request, evidence of worker contracts, payroll records, recruitment fee policies, agency agreements, identity checks and any third–party audit reports.
  • Recruitment and agency checks — Where suppliers use recruitment agencies or labour providers, they must demonstrate ethical recruitment practices, confirm that no worker–paid recruitment fees are charged and provide evidence of agency vetting and worker protections.

Ongoing Monitoring and Assurance

  • Annual attestations — Tier 1 suppliers must provide an annual compliance attestation confirming they and their subcontractors comply with modern slavery obligations and this policy.
  • KPIs and reporting — Suppliers will be measured against KPIs such as completion rates for modern slavery questionnaires, corrective action closure rates, training completion for workers and managers, and number of incidents reported and remediated.
  • Enhanced monitoring for high risk — For suppliers assessed as high risk, MMP will require periodic documentary checks, remote interviews with workers, and where necessary, independent third–party audits.
  • Record keeping — Suppliers must retain records of due diligence, audits, worker contracts, payroll and remediation actions for a minimum of 7 years and make them available to MMP on request.

Worker Protections and Recruitment Practices in the Supply Chain

  • No worker–paid fees — Suppliers must ensure that no worker is required to pay recruitment fees or related costs; where fees have been paid, suppliers must reimburse the worker promptly.
  • Freedom of movement and documents — Suppliers and subcontractors must not retain workers’ identity documents or passports except where legally required and with the worker’s informed consent; any retention must be documented and reversible.
  • Safe reporting channels — Suppliers must provide accessible, confidential channels for workers to raise concerns and must not penalise workers for reporting. Suppliers must share details of these channels with MMP on request.

Subcontracting Controls and Approvals

  • Prior approval for subcontracting — Suppliers must obtain MMP’s written approval before engaging subcontractors for critical or high–risk activities. Approval will be conditional on the subcontractor meeting our modern slavery requirements.
  • Cascade requirement — Suppliers must include a clause in all subcontracts requiring the subcontractor to comply with the same modern slavery obligations and to flow those obligations further down the chain.

Remediation, Victim Support and Cooperation

  • Immediate protection — Where victims are identified within a supplier’s operations or supply chain, suppliers must take immediate steps to protect the victim, including safe accommodation, medical support and access to authorities.
  • Cooperation with investigations — Suppliers must cooperate with MMP, law enforcement and relevant authorities in any investigation and support remediation and victim support measures.
  • Cost allocation — Suppliers are responsible for costs arising from their failure to prevent modern slavery in their operations or supply chain, including remediation costs, unless otherwise agreed.

Consequences of Non–Compliance

  • Corrective action — Minor breaches will require a corrective action plan and monitoring.
  • Sanctions — Repeated or serious breaches may result in suspension, financial penalties (where contractually permitted), termination and reporting to regulatory bodies.
  • Public disclosure — MMP reserves the right to disclose supplier non–compliance publicly where required by law or where it is necessary to protect victims or the public interest.

Support and Capacity Building

  • Supplier guidance — MMP will provide guidance materials and templates (e.g., supplier questionnaire, model contract clause, remediation plan template) to help suppliers meet these requirements.
  • Training — High–risk suppliers and their management teams will be offered targeted training on modern slavery risks, ethical recruitment and remediation best practice.
  • Collaborative remediation — Where appropriate, MMP will work collaboratively with suppliers, NGOs and industry bodies to remediate issues and strengthen systemic protections.

Escalation and Governance

  • Escalation route — Any suspected modern slavery incident in the supply chain must be escalated to Lynn Middleton immediately and reported to the Board where material.
  • Board oversight — The Board will receive periodic reports on supply chain compliance, audit outcomes and remediation activity as part of governance and risk management.

8. Recruitment Labour Providers and Worker Protections

  • Pre–employment checks: All workers must have the right to work verified and identity checks completed in line with UK law and our recruitment procedures.
  • Agency and labour providers: We require agencies and labour suppliers to demonstrate ethical recruitment practices, transparent fee structures (no worker–paid recruitment fees), and compliance with worker rights.
  • Pay and conditions: We expect suppliers to pay at least the applicable legal minimum wage and to provide clear pay slips and working time records.
  • No retention of identity documents: We prohibit retention of passports or ID by employers or recruiters except where legally required and with the worker’s informed consent.
  • Worker voice: We encourage mechanisms for workers to raise concerns confidentially and without fear of retaliation.

9. Training and Awareness

  • Mandatory training for all employees on modern slavery indicators, reporting routes and responsibilities.
  • Targeted training for procurement, HR, contract managers and staff with supplier contact, covering PPN 009/23 expectations and enhanced due diligence.
  • Supplier awareness: We communicate expectations to suppliers and guide compliance and reporting.

10. Reporting, Whistleblowing and Confidentiality

  • Reporting channels: Employees, workers and third parties may report concerns via internal reporting channels, the whistleblowing hotline, or directly to the safeguarding lead. Contact details: lynn@militarymedicalpersonnel.com
  • Confidentiality and protection: Reports will be treated confidentially and investigated promptly. We will protect whistleblowers from retaliation.

11. Monitoring, KPIs and Continuous Improvement

We will monitor the effectiveness of this policy using measurable indicators, including but not limited to:

  • Number and outcome of supplier risk assessments.
  • Percentage of Tier 1 suppliers completing modern slavery questionnaires.
  • Number of staff and supplier training completions.
  • Number of reported incidents and remediation outcomes.
  • Results of supplier audits and corrective action plans.

We will review and update our approach based on monitoring results, changes in legislation, guidance (including PPN 009/23) and best practice.

12. Ethical Trading Initiative Commitment

What is the ETI? The Ethical Trading Initiative (ETI) is a leading alliance of companies, trade unions and NGOs that promotes respect for workers’ rights around the globe through practical, collaborative approaches.

MMP Commitment to ETI Principles

  • Adopt ETI Base Code Principles — We commit to aligning our policies and supplier expectations with the ETI Base Code, including freedom of association, no forced labour, no child labour, safe working conditions, and fair wages.
  • Supplier alignment — We will encourage and require suppliers to adopt ETI–aligned practices and to demonstrate progress through evidence, audits or third–party verification where appropriate.
  • Collaboration — We will engage with industry initiatives, NGOs and peers to share learning and improve protections for workers across our supply chains.
  • Continuous improvement — Where full ETI membership is not immediately practicable, we will adopt ETI principles and work towards demonstrable alignment, documenting progress in our Modern Slavery Statement and supplier communications.

13. Actions to Reduce the Risk of Modern Slavery

Policy and Contractual Measures

  • Include modern slavery clauses in all relevant contracts and require flow–down to subcontractors.
  • Require supplier modern slavery questionnaires and annual attestations.
  • Use risk–based contract approval gates for high–risk categories.

Operational Controls

  • Conduct supply chain mapping for high–risk categories to at least Tier 2 where practicable.
  • Require documentary evidence of worker contracts, payroll and recruitment practices for high–risk suppliers.
  • Implement right–to–audit clauses and carry out targeted audits and worker interviews.

Procurement and Commercial Actions

  • Prioritise suppliers with transparent labour practices and third–party certifications.
  • Include modern slavery risk as a factor in supplier selection and tender evaluation.
  • Use contract incentives and penalties to drive compliance and remediation.

Worker Centred Measures

  • Ensure accessible, confidential grievance mechanisms for workers across the supply chain.
  • Require suppliers to publish or share worker grievance procedures and remediation outcomes.
  • Support worker voice initiatives such as worker committees, hotlines and independent worker surveys.

Capacity Building and Collaboration

  • Provide supplier guidance, templates and training on ethical recruitment and remediation.
  • Offer targeted training to high–risk suppliers and recruitment agencies.
  • Collaborate with NGOs, industry groups and government bodies to address systemic risks.

Remediation and Victim Support

  • Establish clear remediation pathways and require suppliers to fund immediate victim support where they are responsible.
  • Work with specialist organisations to provide safe accommodation, medical and legal support.
  • Document remediation outcomes and lessons learned and feed them into supplier performance reviews.

Data and Reporting

  • Maintain records of due diligence, audits, corrective actions and remediation for a minimum of 7 years.
  • Report progress and incidents in the Modern Slavery Statement and to the Board.

14. Modern Slavery Statement and Publication

  • MMP has not yet reached the statutory turnover threshold of £36 million; however, we voluntarily publish a Modern Slavery Policy on our website, which sets out the steps we take to prevent modern slavery and human trafficking across our operations and supply chain.
  • Where required by law, we will publish an annual Modern Slavery Statement approved at board level and make it available on our website homepage and the Government Registry as required by PPN 009/23.

15. Audit and Assurance

  • We will undertake periodic internal reviews and, where appropriate, independent third–party audits of our modern slavery controls and supplier compliance.
  • Audit findings will be reported to the Board and used to strengthen controls and supplier management.

16. Remediation and Victim Support

  • Where victims are identified, we will prioritise their safety and welfare, cooperate with authorities and support remediation measures.
  • Remediation may include safe accommodation, medical support, legal assistance, repatriation support and financial redress where appropriate. We will seek specialist advice when required.

17. Review and Approval

This policy is approved by:

Name: Lynn Middleton
Job Title: Director
Date: 27/08/2026

This policy will be reviewed at least annually or sooner if required by changes in legislation, guidance (including PPN 009/23), or organisational structure.

18. Contact and Further Information

For questions about this policy, to report concerns, or to request supplier guidance, contact: lynn@militarymedicalpersonnel.com