Introduction
healthya is committed to preventing modern slavery and human trafficking in all its business activities and supply chains. We recognise our responsibility to uphold the highest ethical standards and comply fully with the Modern Slavery Act 2015. This statement sets out the steps we have taken and will continue to take to ensure that modern slavery and human trafficking do not occur within our organisation or our supply chains.
Organisational Structure and Supply Chains
healthya is controlled by a Board of Directors and headquartered in Bolton, UK. We provide staffing and consultancy services primarily to the NHS, primary care, and private sectors via an app, information systems, and face-to-face consultancy formats. Our supply chains consist mainly of UK-based service providers, including staffing agencies, technology partners, and consultancy firms. We maintain oversight of our first-tier suppliers and are committed to increasing transparency throughout our supply chains.
Definitions
Modern slavery includes, but is not limited to:
- Human trafficking
- Forced or compulsory labour, through mental or physical threat
- Child labour and inhumane treatment
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse
- Being dehumanised, treated as a commodity, or being bought or sold as property
- Being physically constrained or having restrictions placed on freedom of movement
Commitment
healthya has a zero-tolerance policy towards modern slavery. This policy applies to all employees, contractors, suppliers, and business partners. We will not enter into or continue business with any organisation that knowingly supports or is found to be involved in slavery, servitude, forced or compulsory labour, or human trafficking.
The Board of Directors has approved this statement and is responsible for its implementation and ongoing review.
Risk Assessment and Management
healthya conducts annual risk assessments to identify and prioritise areas of potential exposure to modern slavery within its operations and supply chains. These assessments inform our due diligence and supplier engagement strategies, with a focus on high-risk areas. Risk assessments are reviewed annually and whenever significant changes occur.
Due Diligence Processes
We conduct due diligence on all new suppliers and regularly review existing suppliers to assess and address risks of modern slavery. Our due diligence activities include:
- Supplier risk assessments and questionnaires
- Contractual obligations requiring compliance with anti-slavery laws
- Periodic supplier audits
- Ongoing monitoring of supplier practices
Any supplier found to be non-compliant will be subject to corrective action or termination of the business relationship.
Key Performance Indicators (KPIs)
We monitor the effectiveness of our anti-slavery measures through the following KPIs:
- Number of supplier audits completed
- Percentage of employees trained on modern slavery
- Number of modern slavery concerns reported and addressed
Training and Awareness
All employees receive training on modern slavery awareness during induction and annual refresher training. Targeted training is provided to staff with specific responsibilities for managing modern slavery risks. This ensures all staff understand the risks and know how to report concerns.
Reporting Concerns
healthya encourages the use of its Whistleblowing Policy to report any concerns regarding modern slavery. Reports can be made confidentially, and all complaints are investigated thoroughly in accordance with our policy.
Policies and Governance
healthya has a Corporate Social Responsibility Policy and a Whistleblowing Policy, both of which reinforce our commitment to ethical conduct and the prevention of modern slavery. The Business Compliance Officer is responsible for overseeing compliance with this policy and conducts an annual review to ensure ongoing effectiveness and alignment with legal requirements.
Publication and Board Approval
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and applies to all companies within and associated with Healthya. It is reviewed annually for each financial year. This statement has been approved by the Board of Directors on 03/07/2025. It is published on our website and registered with the UK government's modern slavery statement registry, as required by law.