Modern Slavery and Human Trafficking Statement

Our commitment to preventing modern slavery in our business operations and supply chains, pursuant to Section 54 of the Modern Slavery Act 2015.

Financial year: 2025/26

Published: 15 April 2026

Status: Voluntary statement

1. Introduction

This statement is made on behalf of The National Health and Medical Services Group of Companies ("NHMS") in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps we have taken, and continue to take, to ensure that modern slavery and human trafficking are not taking place within our business or our supply chains.

Modern slavery is a serious crime and a fundamental violation of human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking. NHMS has a zero-tolerance approach to modern slavery in all its forms.

Although NHMS does not currently meet the £36 million turnover threshold that triggers a mandatory reporting obligation under Section 54, we have chosen to publish this statement voluntarily. As a group whose purpose is the acquisition and operation of businesses supplying the NHS, we consider it important to demonstrate our commitment to ethical business practices from the outset.

2. Our Organisation and Structure

The National Health and Medical Services Group of Companies is a UK-registered group established to acquire and develop owner-managed businesses that supply products and services to NHS hospitals across England. NHMS operates as a parent holding company with wholly owned operating subsidiaries.

As a buy-and-build group focused on the NHS supply sector, our operations will span multiple product and service categories, including clinical and non-clinical consumables, medical equipment, healthcare training, and specialist services. Our supply chains therefore will involve UK-based manufacturers, distributors, and service providers, many of whom interact directly with NHS trusts and integrated care boards.

As NHMS acquires additional businesses, each operating company will be required to adhere to the standards and policies set out in this statement.

3. Our Supply Chains

NHMS and its operating companies will source goods and services from a range of suppliers. These include:

Manufacturers and distributors of clinical and non-clinical consumables (wound care products, continence products, cleaning supplies, uniforms, PPE)
Training and professional development providers
Technology and software service providers
Professional services firms (legal, financial, compliance)
Office supplies, facilities management, and logistics providers

We recognise that certain categories within our supply chains carry higher inherent risk of modern slavery, particularly where products involve manual manufacturing processes, originate from countries with weaker labour protections, or involve low-paid or migrant workforces. NHS England's own review has identified surgical instruments, gloves, gowns, uniforms, and face masks as among the highest-risk product categories in healthcare supply chains. We take account of this evidence in our own risk assessments.

4. Our Policies

NHMS maintains the following policies and procedures relevant to the prevention of modern slavery:

Anti-Slavery and Human Trafficking Policy — Sets out our commitment and expectations for all employees, contractors, and suppliers. Prohibits the use of forced, bonded, or compulsory labour in any form.
Supplier Code of Conduct — Requires all suppliers to confirm their compliance with the Modern Slavery Act 2015 and to take reasonable steps to ensure there is no slavery or trafficking in their own supply chains.
Whistleblowing Policy — Provides a confidential mechanism for employees, contractors, and third parties to report concerns about suspected modern slavery or any other unethical practices without fear of retaliation.
Recruitment and Employment Policy — Ensures robust pre-employment checks, including verification of identity and right to work in the UK, for all directly employed staff. We do not charge recruitment fees to candidates.
Ethical Procurement Policy — Integrates modern slavery risk considerations into supplier selection, onboarding, and ongoing contract management.

5. Due Diligence Processes

NHMS applies due diligence procedures both in its acquisition activities and in its ongoing supplier management. These include:

Acquisition due diligence: When evaluating potential acquisition targets, we assess the company's existing employment practices, supplier relationships, and compliance with the Modern Slavery Act as part of our standard due diligence process.
Supplier onboarding: New suppliers are required to confirm their compliance with the Modern Slavery Act and to provide their own modern slavery statement where applicable. Where a supplier does not meet the statutory reporting threshold, we ask them to confirm the steps they take to identify and prevent modern slavery in their operations.
Ongoing monitoring: We review supplier compliance periodically and require suppliers on significant contracts to confirm their continued adherence to our Supplier Code of Conduct.
NHS frameworks alignment: Where our operating companies supply goods or services through NHS Supply Chain frameworks or directly to NHS trusts, we comply with the applicable NHS terms and conditions, which include specific provisions related to modern slavery and ethical procurement.

6. Risk Assessment and Management

We assess modern slavery risk by reference to the following factors:

Country risk: Whether goods or raw materials originate from, or transit through, countries with a higher prevalence of forced labour or weaker regulatory enforcement.
Sector risk: Whether the product category involves labour-intensive manufacturing, agricultural inputs, or sectors identified as high-risk by the Home Office or NHS England.
Workforce risk: Whether the supply chain involves temporary, agency, or migrant workers who may be more vulnerable to exploitation.
Transparency risk: The extent to which suppliers are able and willing to provide visibility into their own sub-tier supply chains.

Where elevated risk is identified, we will engage directly with the supplier to understand their mitigation measures and, where appropriate, require additional assurances or corrective action.

7. Training

All NHMS personnel involved in procurement, supplier management, or recruitment will be provided with guidance on recognising the indicators of modern slavery and human trafficking, and on the procedures for reporting concerns. This includes awareness of the Modern Slavery Helpline (08000 121 700) and the relevant escalation pathways.

As NHMS grows, we will develop a structured training programme appropriate to the scale and nature of our operations, ensuring that staff across our operating companies are equipped to identify and respond to modern slavery risks.

8. Measuring Effectiveness

We will assess the effectiveness of our approach to preventing modern slavery through the following measures:

The proportion of new suppliers who have confirmed compliance with the Modern Slavery Act or provided equivalent assurances
Completion of modern slavery awareness guidance by relevant personnel
The number and nature of any concerns raised through our whistleblowing or reporting channels
The outcome of any due diligence findings related to modern slavery risk during acquisition processes
Year-on-year progress against our stated commitments in this and subsequent statements

We are committed to monitoring our progress, including acknowledging areas where further work is required.

9. Our Commitment Going Forward

In the coming years, we intend to:

Formalise and publish our Supplier Code of Conduct, including specific modern slavery provisions
Embed modern slavery due diligence as a standard element of our acquisition checklist
Develop staff training materials tailored to the NHS supply sector
Engage with NHS England's guidance on tackling modern slavery in NHS procurement, including the Modern Slavery Assessment Tool (MSAT), as applicable to our operating companies
Review and update this statement annually, reflecting the growth of the group and any changes in risk profile

Reporting Concerns

If you have any concerns about modern slavery or human trafficking in connection with NHMS or any of its operating companies, please contact us at compliance@nhms.health.

You may also contact the Modern Slavery Helpline on 08000 121 700 or visit www.modernslaveryhelpline.org.