Modern Slavery & Human Trafficking Policy

1. Purpose and values

Newman Healthcare Ltd is committed to preventing modern slavery and human trafficking in its operations and business relationships. Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. It is a serious abuse of human rights and is incompatible with safe, ethical healthcare.

This policy supports our commitment to compassionate, person-centred care, dignity, respect, inclusion and safety. The wellbeing and freedom of the people we support, our staff and everyone involved in delivering our services must be protected. We take a zero-tolerance approach to exploitation and will act on concerns promptly and fairly.

2. Scope and accountability

This policy applies to directors, employees, temporary and agency workers, contractors and volunteers working for or on behalf of Newman Healthcare Ltd. Suppliers, recruitment partners and other business partners are expected to meet equivalent standards.

America Nwani Iwerumor, Director, is responsible for overseeing implementation, ensuring concerns are addressed and reviewing this policy. Managers must communicate the requirements, assess risks and escalate concerns. Everyone covered by this policy must remain alert to exploitation and report concerns without delay.

3. Risk assessment

Managers must assess modern slavery risks within the services and supply chains the company actually uses. Relevant areas may include recruitment agencies, international recruitment, subcontracted services, payroll providers, cleaning, uniforms, personal protective equipment and other healthcare supplies.

Higher-risk arrangements require additional checks. Warning signs include recruitment debt, threats linked to employment or immigration status, withheld identity documents, unexplained wage deductions, restricted movement, or another person controlling a worker's pay or communications. Shared accommodation or bank details alone do not prove exploitation; concerns must be assessed sensitively and without discrimination.

4. Ethical recruitment and working conditions

• ✓Verify identity, entitlement to work, references and role-specific qualifications or checks where required. Speak directly with candidates and ensure that they understand the role, pay, hours and contractual terms before accepting work.
• ✓Do not charge workers recruitment fees to obtain employment with Newman Healthcare Ltd. Recruitment partners must not use debt, coercion or misleading promises to secure labour. Investigate any indication that a worker has paid improper fees.
• ✓Do not retain original passports or identity documents to control workers. Workers must be free to leave employment in accordance with lawful contractual terms and must not face threats or penalties amounting to forced labour.
• ✓Pay wages in accordance with applicable law, provide clear payslips and ensure deductions are lawful and transparent. Confirm workers retain control of their earnings and can raise payroll concerns privately.
• ✓Provide safe working conditions, appropriate rest and accessible ways to raise concerns. Check agency and subcontracting arrangements proportionately; right-to-work checks alone do not establish that a worker is free from exploitation.

5. Suppliers and business partners

Before engaging a supplier or recruitment partner, the responsible manager must conduct checks proportionate to the risk. These should consider business identity, recruitment practices, subcontracting, labour conditions and any relevant modern slavery policy or statement. Higher-risk partners may require supporting evidence, worker feedback or further review.

Relevant contracts should require compliance with applicable anti-slavery laws, prohibit forced labour and worker-paid recruitment fees, and require cooperation with investigations and corrective action. Maintain records of checks, concerns and agreed improvements, and review suppliers when risks or circumstances change.

Where concerns arise, prioritise the safety of affected people. Require proportionate corrective action and monitor progress. Suspend or end a relationship where serious risks cannot be addressed, considering the potential impact on workers and taking advice where necessary.

6. Training and awareness

Staff must receive information about this policy during induction and periodic refreshers appropriate to their role. Managers and colleagues involved in recruitment, procurement and safeguarding should receive additional guidance on identifying exploitation, responding sensitively and reporting concerns. Keep records of training and follow up gaps.

7. Reporting concerns and protecting people

Anyone who suspects exploitation involving a worker, candidate, person receiving care or supplier must report the concern promptly to their line manager or the Director. If that person is implicated, unavailable or does not act, use another appropriate manager or report externally. A person does not need proof before raising a concern in good faith.

Listen calmly, take the person seriously and avoid promises of absolute confidentiality. Do not confront a suspected exploiter or conduct an investigation that could increase risk. Record facts and the person's own words securely, share information only where necessary and lawful, and use an independent interpreter where needed.

Newman Healthcare Ltd will not tolerate retaliation against anyone who raises a genuine concern or assists an investigation. Managers must respond promptly, consider immediate protection and support, cooperate with relevant authorities and keep an appropriate record of actions and outcomes.

8. Monitoring, review and legal reporting

The Director will review this policy at least annually and following significant incidents or changes in law or operations. Review measures should include completion of training, recruitment and supplier checks, concerns raised, response times and corrective actions. An absence of reports must not be treated as proof that exploitation is absent.

This document sets policy requirements; it does not certify actions completed in a particular financial year. The company must assess whether section 54 of the Modern Slavery Act 2015 applies. Where an annual statement is required, it must describe the actual steps taken for the relevant financial year and meet the applicable approval, signature and publication requirements.