Modern Slavery and Human Trafficking Policy

Last updated: 24 September 2026

Our commitment

Open Hearts Healthcare Ltd is committed to conducting its business ethically and responsibly and to preventing modern slavery, human trafficking, forced labour and exploitation within our business activities and relationships.

We recognise our responsibility to promote fair and lawful working practices and to remain alert to the risk of exploitation, particularly within recruitment and healthcare staffing.

What is modern slavery?

Modern slavery may take a number of forms, including:

• forced or compulsory labour;
• human trafficking;
• slavery or servitude;
• debt bondage;
• exploitation of vulnerable workers; and
• other situations in which an individual is forced to work or is unable to leave employment freely.

Open Hearts Healthcare Ltd does not tolerate modern slavery or human trafficking in any part of its business.

Recruitment practices

As a healthcare staffing provider, we are committed to fair, ethical and transparent recruitment.

We will:

• verify workers’ identity and right to work in the UK;
• undertake appropriate recruitment and compliance checks;
• provide workers with clear information about their role and working arrangements;
• not knowingly use forced, trafficked or unlawfully exploited labour;
• not require workers to surrender passports or other original identity documents as a condition of working for us;
• not knowingly participate in recruitment arrangements involving coercion or unlawful recruitment fees; and
• take concerns about exploitation seriously.

Our staff and workers

We expect everyone working for or representing Open Hearts Healthcare Ltd to treat colleagues, workers, clients and other individuals fairly and with dignity and respect.

Workers should be free to raise concerns about working practices without fear of retaliation.

Clients, suppliers and business partners

We expect organisations with which we work to conduct their operations lawfully and ethically.

Where appropriate, we may consider modern slavery risks when selecting or reviewing suppliers and business relationships.

If we become aware of credible concerns relating to exploitation, forced labour or human trafficking within our supply chain or business relationships, we will consider appropriate action.

This may include seeking further information, requiring corrective action, suspending a relationship, terminating a relationship or reporting concerns to the appropriate authorities where necessary.

Identifying concerns

Possible indicators of exploitation may include situations where an individual:

• appears frightened, controlled or reluctant to communicate independently;
• is unable to access their own identity documents;
• appears to have been coerced into employment;
• is being controlled by another person in relation to their pay or working arrangements;
• is unable to leave their employment freely; or
• shows other signs that may indicate trafficking, forced labour or exploitation.

The presence of one indicator does not necessarily mean that modern slavery is taking place, but concerns should be taken seriously.

Reporting concerns

Anyone who has a concern relating to modern slavery or human trafficking connected with Open Hearts Healthcare Ltd should report it as soon as possible.

Concerns can be raised by contacting:

info@openheartshealthcare.co.uk

We will consider concerns appropriately and, where necessary, refer matters to relevant authorities or safeguarding organisations.

Responsibility

Open Hearts Healthcare Ltd is responsible for maintaining appropriate measures to reduce the risk of modern slavery within its activities.

Managers and those involved in recruitment are expected to remain alert to potential indicators of exploitation and to escalate concerns appropriately.

Compliance with the Modern Slavery Act 2015

Open Hearts Healthcare Ltd will comply with the Modern Slavery Act 2015 and any other applicable legal requirements.

Where the company becomes subject to the statutory transparency requirements under section 54 of the Modern Slavery Act 2015, it will prepare and publish the required annual modern slavery statement in accordance with the legislation.

Review

This policy will be reviewed periodically and updated where necessary to reflect changes in legislation, guidance or our business activities.