Modern Slavery Policy

Version	2.0
Effective date	01/01/2026
Approved by	Hiren Patel, Director
Next review	01/01/2027, or sooner if the law or our operations change

1. Policy statement and scope

Remity Staffing Solution Ltd (“Remity”) has zero tolerance for modern slavery, human trafficking, forced labour and labour exploitation in our business and supply chain. We supply nurses, healthcare assistants, doctors, allied health professionals, social workers and non-clinical staff to NHS trusts, hospitals and care providers. Because we recruit and place people, we recognise that we can be a route to exploitation if our controls fail.
This policy applies to:

all Remity employees, directors and office staff in the UK;
all temporary workers, locums and contractors we register or place in the UK, however they are paid
(PAYE, umbrella company, limited company or direct engagement);
our suppliers and partners, including umbrella companies, payroll providers, recruitment partners, training and occupational health providers, and accommodation or transport providers

2. What modern slavery is

Modern slavery is a serious crime and a violation of human rights. It covers any situation where a person is controlled and exploited for someone else’s gain and cannot freely leave. Under the Modern Slavery Act 2015, it includes:

Slavery, servitude and forced or compulsory labour. A person is made to work, or held in a situation, through threats, force, deception or coercion.
Human trafficking. Someone arranges or helps another person’s travel, within the UK or across borders, so that they can be exploited.
Debt bondage. A worker is kept in work to repay a debt that is inflated, unclear or impossible to clear. This often comes from recruitment fees, travel or accommodation costs.

Poor employment practice is not the same as modern slavery, but it can be an early warning sign. Examples include underpayment of the National Minimum Wage, excessive working hours or denied rest breaks. Remity treats these as serious compliance failures in their own right and investigates them. We also assess them as possible indicators of exploitation (see section 8).

3. Legal and regulatory framework

Law or requirement	What it means for Remity
Modern Slavery Act 2015	Sets out the offences in section 2. Section 54 requires an annual transparency statement from organisations with turnover of £36 million or more. Remity adopts this policy voluntarily and will publish a section 54 statement if we reach that threshold.
Employment Agencies Act 1973 and Conduct of Employment Agencies and Employment Businesses Regulations 2003	We must not charge workers fees for finding them work. We must also keep proper terms, records and checks.
Immigration, Asylum and Nationality Act 2006	We must complete and record right-to-work checks before any placement.
National Minimum Wage Act 1998 and Working Time Regulations 1998	Workers are paid at least the legal minimum. The 48-hour weekly limit is averaged over 17 weeks, and rest breaks apply. Any worker may opt out of the 48-hour limit, but only voluntarily and in writing, and the opt-out is kept on file.
Employment Rights Act 2025	Set up the Fair Work Agency (FWA), which started on 7 April 2026. The FWA now enforces employment agency standards and investigates labour exploitation, and can inspect agencies.
Procurement Act 2023	Public bodies, including NHS buyers, can exclude suppliers linked to modern slavery offences. A breach could cost Remity its framework and trust contracts.
NHS workforce frameworks and the Code of Practice for international recruitment	Framework audits check that we hold a modern slavery policy and operate it. We must also recruit ethically and not actively recruit from countries on the WHO health workforce support and safeguards list.

4. Roles and responsibilities

Role	Responsibility
Director (Hiren Patel)	Has overall accountability and day-to-day ownership of this policy. Approves it each year and ensures adequate resources. Keeps controls, training and supplier checks up to date. Receives and investigates concerns and keeps the concerns log.
Compliance team	Carries out registration, identity, right-to-work and payroll checks, and escalates anything suspicious to the Director.
Recruitment and account managers	Watch for indicators when speaking to candidates and clients, and report concerns the same day.
All staff and workers	Read and follow this policy, complete training, and report any suspicion.

5. Risk areas in our business

We have assessed where exploitation is most likely to arise in healthcare staffing:

International recruitment. Overseas workers may have paid fees to third-party agents or taken on loans for travel and visas. They may also be unfamiliar with UK rights.
Third-party control of workers. Another person may run a worker’s bank account, phone or email, arrange their shifts, or hold their passport or ID.
Umbrella companies and payroll intermediaries. Unlawful deductions, non-compliant pay models or unclear payslips can hide underpayment.
Excessive hours. Workers may take shifts across several agencies or be pressured into long hours.
Accommodation and transport. Housing or travel supplied by a third party can create debt or dependency.

6. Controls in recruitment, registration and placement

No fees to workers. Remity never charges candidates for finding them work. We do not work with any agent or partner who does
Face-to-face or video identity check. Every worker is verified in person or by live video against original documents. They must keep their own documents.
Right-to-work checks. These are completed and recorded before the first shift, with follow-up checks before any time-limited permission ends.
Unique contact and bank details. A worker must have their own phone, email and bank account. We flag shared addresses, phone numbers or accounts across worker records and investigate them.
Clear terms in a language the worker understands. This includes pay rates, deductions, the working time opt-in or opt-out, and how to raise concerns.
Interview questions about exploitation. At registration we ask how the worker found us, whether they paid anyone to get work, and who arranges their housing and travel.
Pay and hours monitoring. We check timesheets and payslips against agreed rates and rest rules, and review workers with very high hours across placements.
Ethical international recruitment. We follow the NHS Code of Practice for international recruitment and do not actively recruit from WHO safeguard-list countries.
Umbrella company controls. We use only umbrella companies that pass our due diligence, and we have a written contract with each (see section 7).

7. Supplier and supply chain due diligence

Before we appoint a supplier, we rate its modern slavery risk and apply checks to match. Higher-risk suppliers include umbrella companies, payroll providers, overseas recruitment partners and accommodation providers.

All suppliers. They must sign our anti-slavery clause or declaration. This commits them to our standards, gives us audit rights, and lets us end the relationship if they breach it.
Umbrella and payroll providers. We require recognised accreditation, sample payslip checks, confirmation that no unlawful deductions or fees are charged, and a signed indemnity.
Overseas recruitment partners. We require written confirmation that they charge candidates no fees, evidence of their licence where their country requires one, and our right to audit them.

We review high-risk suppliers every year and all others at contract renewal. If we find a problem, we agree a remedy plan with a deadline. If it is not fixed, or the problem is serious, we end the relationship.

8. Indicators to look out for

No single sign proves exploitation, but any of these should be reported:

someone else holds the worker’s passport, ID or bank card;
another person always attends interviews, speaks for the worker, or collects them from shifts;
the worker shares bank details, a phone number or an address with several other workers;
the worker mentions a debt to an agent or employer, or says they paid to get work;
the worker cannot say where they live, or lives in housing that someone else controls;
the worker appears fearful, withdrawn, malnourished or unusually tired;
the worker works very high hours with little rest, or says they cannot refuse shifts;
pay goes to someone else, or the worker has unexplained deductions.

9. Reporting concerns and how we respond

If someone is in immediate danger, call 999.

For any other concern, tell your manager or the Director the same day. You can also report under our Whistleblowing Policy, including anonymously. Outside Remity, you can contact:

the Modern Slavery and Exploitation Helpline on 08000 121 700 (24 hours, free, confidential);
the police on 101 for non-emergencies;
the Fair Work Agency, for concerns about employment agencies or labour exploitation.

When we receive a concern, the Director will:

log it and assess the risk to the worker within 24 hours;
put the worker’s safety first and never confront a suspected exploiter in a way that could put anyone at risk;
refer the matter to the police, local authority or Fair Work Agency where appropriate, so a victim can be referred to the National Referral Mechanism for support;
tell the affected NHS or care client where the placement is affected, as our contracts require;
record the outcome and any changes made to our controls.

No one will suffer detrimental treatment for raising a concern in good faith, even if it turns out to be mistaken.

10. Training

Office staff and managers. Modern slavery awareness training at induction, refreshed every year. Recruitment and compliance staff also receive training on the indicators in section 8.
Temporary workers. A modern slavery module forms part of mandatory training at registration. It covers their rights, how to spot exploitation and how to report it.
Records. Training completion is recorded and reported to the Director.

11. Breaches of this policy

An employee who breaches this policy, or ignores or fails to report a concern, will face disciplinary action. This may include dismissal for gross misconduct. A worker, supplier or partner who breaches it may have their placement or contract ended. Where a crime may have been committed, we will report it to the authorities.

12. Monitoring and review

The Director reviews these measures every quarter:

Measure	Target
Office staff with in-date modern slavery training	100%
New workers with face-to-face or video ID and right-to-work checks before first shift	100%
High-risk suppliers with a signed declaration and annual review	100%
Shared bank, phone or address flags investigated	100% within 5 working days
Concerns reported, and their outcomes	Recorded and reviewed

The Director reviews this policy at least once a year. It is also reviewed after any incident or change in the law, and we use the results to improve our controls. Staff are welcome to suggest improvements. This policy does not form part of any employee’s contract of employment and may be amended at any time.

13. Approval

This policy has been approved by the Board of Directors of Remity Staffing Solution Ltd.

Signed on behalf of the Supplier
Name	Hiren Patel
Position	Director
Signature
Date	02/02/2026

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