Modern Slavery and Human Trafficking Policy

1. Policy Statement

PLE Health Ltd is committed to preventing modern slavery and human trafficking in all aspects of its business operations and supply chains. We have a zero-tolerance approach to slavery, servitude, forced or compulsory labour, debt bondage and human trafficking. We are committed to acting ethically, with integrity and transparency in all business relationships and implementing effective systems and controls to minimise the risk of modern slavery. PLE Health expects the same high standards from employees, workers, contractors, suppliers, agency partners and business associates.

2. Purpose

• Prevent modern slavery and human trafficking.
• Ensure compliance with the Modern Slavery Act 2015.
• Protect workers and vulnerable individuals.
• Promote ethical recruitment.
• Establish reporting procedures.

3. Scope

This policy applies to directors, employees, agency workers, contractors, consultants, temporary workers, volunteers, suppliers, recruitment agencies and business partners.

4. Definition

Modern slavery includes human trafficking, forced labour, compulsory labour, debt bondage, servitude, exploitation and unlawful child labour.

5. Our Commitment

PLE Health will operate ethically, ensure employment is freely chosen, verify right to work, never retain passports, never charge recruitment fees, use reputable recruitment agencies, and require suppliers to uphold equivalent standards.

6. Responsibilities

The Board oversees compliance. Managers promote awareness and report concerns. Employees must comply with this policy, report suspected modern slavery and complete required training.

7. Recruitment

PLE Health will conduct lawful recruitment, identity and right-to-work checks, provide written contracts and ensure workers understand their employment terms.

8. Supply Chain

Suppliers are expected to comply with the Modern Slavery Act 2015, maintain lawful employment practices and cooperate with due diligence. PLE Health may require corrective action or terminate relationships where serious concerns exist.

9. Identifying Risk

Potential indicators include withheld identity documents, intimidation, fearfulness, restricted movement, unexplained wage deductions, multiple workers sharing bank accounts without explanation and inability to speak freely.

10. Reporting Concerns

Concerns should be reported to a Line Manager, HR, the Compliance Lead or a Director. Reports will be investigated appropriately and those raising genuine concerns in good faith will be protected from retaliation.

11. Training

Appropriate awareness training will be provided, particularly for recruitment, procurement, HR, managers and clinical teams.

12. Monitoring and Review

Compliance will be monitored through recruitment audits, supplier due diligence, internal audits, incident reporting and annual policy reviews.

13. Related Policies

Safeguarding, Whistleblowing, Recruitment & Selection, Equality Diversity & Inclusion, Code of Conduct, Procurement, Anti-Bribery & Corruption.

14. Non-Compliance

Failure to comply may result in disciplinary action, termination of contracts, supplier sanctions and referral to relevant authorities where appropriate.