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Modern Slavery and Human Trafficking Statement 2025/26

Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by HealthHarmonie Limited (“HealthHarmonie”) to prevent modern slavery and human trafficking in its operations and supply chains.

1. Organisational Structure and Supply Chains

HealthHarmonie provides high-quality community services to NHS organisations across the UK. We have a network of clinicians, managers, and operational staff who work with NHS Integrated Care Boards and NHS Trusts to support the delivery of community services. Our supply chain primarily involves workforce recruitment, clinical and premises equipment hire, and IT and logistics support. While relatively low-risk compared to manufacturing sectors, we recognise potential risks associated with third-party agencies and service providers.

2. Policies in Relation to Modern Slavery and Human Trafficking

HealthHarmonie has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all business dealings and relationships.

Key internal policies supporting this include:

  • Anti-Slavery and Human Trafficking Policy

  • Safeguarding Adults and Children Policy

  • Whistleblowing Policy

  • Freedom to Speak Up Policy

  • Recruitment and Vetting Policy

These are reviewed regularly and communicated to all staff and relevant stakeholders.

3. Due Diligence Processes

We conduct due diligence on all new suppliers and review existing ones based on risk. Our process includes:

  • Reviewing supplier policies on ethical labour practices

  • Including anti-slavery clauses in contracts

  • Requiring suppliers to confirm their compliance with the Modern Slavery Act (if applicable)

  • We are embedding our due diligence process into procurement templates and onboarding workflows.

4. Risk Assessment and Management

We assess modern slavery risks based on:

  • Sector-specific vulnerabilities (e.g., recruitment, logistics)

  • Geographic location of suppliers

  • Type of labour used

Where risks are identified, enhanced checks are conducted, including documentation reviews and, where applicable, supplier audits.

We are exploring integration of NHS guidance and tools such as the Evergreen Sustainable Supplier Assessment and aligning to Procurement Policy Note 02/23 to further strengthen our approach.

5. Effectiveness and Monitoring

We monitor the effectiveness of our approach by:

  • Tracking policy breaches or concerns raised

  • Logging safeguarding and whistleblowing reports

  • Conducting annual internal policy reviews

  • Monitoring supplier compliance declarations

We are developing performance metrics to better track improvements over time.

6. Training on Modern Slavery

All HealthHarmonie staff complete annual safeguarding training, which includes modern slavery awareness. Additional guidance is provided to managers and recruiters on identifying risks and handling concerns.

7. Reporting Concerns

HealthHarmonie encourages a culture of openness. Concerns can be raised confidentially via:

  • Line managers

  • Our internal safeguarding team

  • External whistleblowing hotlines (e.g. Modern Slavery Helpline: 0800 0121 700)

  • The Company CEO

We ensure there is no victimisation for raising genuine concerns.

Tim Flanagan,

CEO HealthHarmonie Limited

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