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Slavery & Human Trafficking
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the steps taken by Personal Homecare Pharmacy Ltd to prevent modern slavery and human trafficking within our business operations and supply chains during the financial year ending 31 March 2026.
Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. Personal Homecare Pharmacy Ltd recognises that modern slavery is a serious crime and a violation of fundamental human rights.
This statement is intended to provide transparency regarding the steps taken by the business during the relevant financial year. It does not imply that Personal Homecare Pharmacy Ltd can guarantee that modern slavery does not exist anywhere within its wider supply chain; however, it confirms the steps we have taken and continue to take to identify, assess, mitigate and respond to risk.
Our Organisation
Personal Homecare Pharmacy Ltd is a UK-based homecare pharmacy provider delivering pharmaceutical dispensing, clinical support, and homecare services across the United Kingdom. The company employs approximately 99 employees and operates within regulated healthcare and pharmaceutical sectors.
We are committed to conducting business ethically, transparently, and with integrity. We recognise our responsibility to identify and mitigate the risks of modern slavery, forced labour, servitude, and human trafficking within both our organisation and supply chain.
As a regulated healthcare provider, we understand the importance of maintaining robust governance, compliance, safeguarding, quality assurance and workforce controls. These controls support our commitment to protecting workers, patients, service users, suppliers and the wider public from exploitation and unethical practice.
Our Supply Chains
Our supply chains include, but are not limited to:
- Pharmaceutical manufacturers and wholesalers
- Medical consumables and packaging suppliers
- Courier and logistics providers
- IT and technology service providers
- Recruitment and temporary staffing agencies
- Facilities management, cleaning, and maintenance services
- Professional consultancy and outsourced services
We acknowledge that certain sectors and geographical regions may present a higher risk of labour exploitation and modern slavery practices, particularly within outsourced services, manufacturing, logistics, and temporary labour arrangements.
We also recognise that risks may be heightened where there are complex supply chains, subcontracting arrangements, overseas labour, low-paid roles, agency labour, migrant workers, or workers who may be vulnerable due to language barriers, immigration status, financial pressure, dependency on accommodation, or lack of awareness of employment rights.
Governance and Responsibility
Responsibility for oversight of this statement sits with the Senior Management Team. The day-to-day responsibility for relevant controls is shared across senior management, the People Team, procurement, quality, compliance and operational management, depending on the nature of the risk or issue identified.
Managers are expected to escalate any concerns relating to suspected exploitation, unethical labour practices, safeguarding, recruitment irregularities, supplier misconduct, or worker vulnerability through the appropriate internal reporting routes.
Our Policies
We operate a range of policies and procedures designed to promote ethical conduct and minimise the risk of modern slavery, including:
- Recruitment and Right to Work Procedures
- Equal Opportunities Policy
- Whistleblowing Policy
- Safeguarding Procedures
- Supplier Approval and Procurement Processes
- Health and Safety Policies
- Employee Code of Conduct
- Grievance and Disciplinary Procedures
These policies support a culture of transparency, accountability, and respect for human rights. We also rely on wider governance and people-management processes, including onboarding checks, probation reviews, absence management, performance management, investigation processes, disciplinary procedures, and internal escalation routes.
Due Diligence Processes
We undertake due diligence measures to assess and reduce the risk of modern slavery within our business and supply chains. These measures include:
- Conducting right to work checks for all employees
- Verifying identity and employment documentation
- Using reputable recruitment agencies and service providers
- Assessing suppliers during onboarding processes
- Reviewing supplier compliance and regulatory standards
- Including ethical and compliance expectations within supplier agreements where appropriate
- Maintaining whistleblowing channels for confidential reporting of concerns
- Investigating concerns raised regarding unethical practices
Where relevant and proportionate, supplier due diligence may include review of company information, regulatory status, insurance, accreditations, professional registrations, contractual arrangements, service standards, and any concerns relating to labour practices, subcontracting or compliance history.
We expect suppliers, contractors and business partners to comply with all applicable employment, immigration, health and safety, equality, safeguarding and modern slavery legislation. We also expect them to take reasonable steps to ensure that modern slavery and human trafficking are not taking place within their own operations or supply chains.
Where concerns are identified, we reserve the right to review, suspend, or terminate supplier relationships.
Where appropriate, we may also require corrective action, further information, additional contractual assurances, or escalation to relevant authorities before deciding whether to continue, suspend or terminate a supplier relationship.
Risk Assessment and Management
As a healthcare and pharmacy provider, we recognise that potential modern slavery risks may arise in areas such as:
- Agency and temporary staffing
- Overseas manufacturing and supply chains
- Logistics and courier operations
- Outsourced support services
- International recruitment practices
To mitigate these risks, we continue to strengthen supplier oversight, workforce verification procedures, and internal governance processes.
Our risk-based approach considers the nature of the service provided, the location of the supplier, the use of agency or subcontracted labour, the level of worker vulnerability, the degree of management oversight, and the potential impact on our regulated operations.
We consider the following areas to be key risk indicators: unexplained recruitment fees, lack of transparency around employment terms, workers appearing fearful or controlled, reluctance to speak independently, inconsistencies in identity or right to work documentation, excessive working hours, poor accommodation arrangements linked to work, unusual payment arrangements, or reports of coercion, intimidation or debt bondage.
Overseas Recruitment and Worker Protection
We are committed to ethical recruitment practices and fair treatment of all workers.
We do not knowingly engage with organisations involved in forced labour, servitude, or exploitative employment practices. We expect all recruitment partners and suppliers to comply with UK employment law and the Modern Slavery Act 2015.
Our controls include:
- Verification of employee identity and right to work status
- Compliance with UK employment legislation
- Fair recruitment and employment practices
- Clear reporting and escalation routes for concerns
- Safeguarding procedures for vulnerable individuals
Where workers are recruited from overseas or where immigration status may be relevant, we seek to ensure that individuals are treated fairly, understand their employment terms, are not charged unlawful recruitment fees and are not placed under improper pressure by any third party.
We do not tolerate the withholding of identity documents, coercive recruitment practices, threats linked to immigration status, or any arrangement that restricts an individual’s freedom to leave employment in accordance with the law.
Training and Awareness
We provide training and awareness to relevant employees to support the identification and reporting of modern slavery concerns.
Training may include:
- Safeguarding awareness
- Whistleblowing procedures
- Ethical conduct and compliance expectations
- Recruitment and employment checks
- Recognition of exploitation indicators
Relevant managers and employees involved in recruitment, procurement, governance, and compliance are expected to understand their responsibilities regarding modern slavery risks.
We will continue to review the need for further targeted awareness for managers and employees involved in recruitment, supplier engagement, facilities, logistics, quality, compliance, and operational management.
Reporting Concerns
Employees, workers, suppliers, contractors and other stakeholders are encouraged to report any concerns relating to suspected modern slavery, human trafficking, forced labour, exploitation, unethical recruitment, or worker abuse.
Concerns may be raised through the appropriate management route, the People Team, safeguarding route, whistleblowing process, or any other suitable escalation channel. Reports will be taken seriously, treated sensitively and reviewed in line with the nature and severity of the concern.
Where there is an immediate risk of harm, or where criminal activity is suspected, the company may escalate concerns to the appropriate external authorities, including law enforcement, safeguarding bodies, regulatory bodies, or the Modern Slavery Helpline, as appropriate.
Measuring Effectiveness
We continue to review the effectiveness of our approach through:
- Monitoring recruitment compliance checks
- Reviewing supplier relationships and onboarding processes
- Investigating any concerns or incidents raised
- Reviewing policies and governance arrangements annually
- Monitoring staff training completion
- Maintaining internal audit and quality management processes
We also monitor the effectiveness of our controls through management oversight, quality assurance processes, audit activity, incident reporting, HR compliance checks and review of any concerns raised through internal reporting routes.
At the date of this statement, no incidents of modern slavery or human trafficking have been identified within our organisation.
Should any concern be identified, we will investigate promptly and take appropriate action, which may include remedial action, supplier review, disciplinary action, referral to external authorities, or termination of relevant business relationships.
Continuous Improvement
We are committed to continuously improving our processes and controls to combat modern slavery and human trafficking. Future objectives include further strengthening supplier due diligence, enhancing staff awareness, and reviewing procurement controls where appropriate.
Board Approval
This statement has been approved by the Board of Directors of Personal Homecare Pharmacy Ltd and will be reviewed annually.
– Updated for the financial year ending 31 March 2026