Primrose Healthcare Solutions Services Limited

 

1. Policy Statement

 

Primrose Healthcare Solutions Services Limited (“the Company”) is committed to conducting its business ethically and with integrity. We have a zero-tolerance approach to modern slavery and human trafficking and are committed to preventing such practices in all areas of our operations and supply chains.

 

Modern slavery encompasses slavery, servitude, human trafficking, and forced labour  — all of which are serious human rights violations.

 

2. Purpose

 

This policy sets out Primrose Healthcare’s commitment to:

•  Preventing modern slavery and human trafficking within our business and supply chains.

•  Complying with the UK Modern Slavery Act 2015.

• Promoting awareness, transparency, and accountability within our organization and among our suppliers.

 

3. Scope

 

This policy applies to:

• All employees, volunteers, and contractors of Primrose Healthcare Solutions Services Limited.

• Registered Manager •

• Other management 

• Suppliers, service providers, and third-party agencies working on our behalf. •

• Service Users                                                                                                                                                                                                                                                                                                       The following stakeholders may be affected by this policy:                                                                 

• Commissioners

• Local Authority

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   4. Risk Areas

As a provider in the healthcare sector, we recognize the following areas of potential risk:

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    Risk Areas                               Risk Level                           Mitigation Measures

   Recruitment via agencies                       High                                           Approved agency list, robust vetting, right-to-work checks

   Outsourced services

   (e.g., cleaning, maintenance)                  Medium– High                       Supplier due diligence, contractual controls.

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    Care staff from overseas                           High                                         Ethical recruitment practices, full compliance with                                                                                                                                                   immigration laws

    Supply chain (e.g., uniforms, PPE)          Medium                                  Supplier audits, transparency requirements

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​5. Responsibilities

 

Management Responsibilities

• Ensure this policy is implemented and reviewed annually.

• Conduct modern slavery risk assessments across services and suppliers.

• Include anti-slavery terms in supplier and staff contracts.

Employee Responsibilities

•   Read and comply with this policy.

•  Be alert to signs of modern slavery or trafficking.

•  Report any concerns confidentially.

6. Due Diligence

• We will:

•  Vet all suppliers, contractors, and recruitment partners for modern slavery risks.

•  Require high-risk suppliers to complete a Modern Slavery Questionnaire.

•  Maintain records of due diligence efforts and actions taken.

7. Recruitment Practices

•  All employees must provide valid proof of identity and right to work in the UK.

•  No recruitment fees are paid by workers.

•  All contracts are explained in a language the employee understands.

•  Workers are free to leave employment with appropriate notice.

8. Reporting Concerns
If you suspect modern slavery or human trafficking, you should:

1. Report to your line manager or designated safeguarding lead.

2. Alternatively, use our anonymous whistleblowing service:

 

Email: info@primrosehealthcaresolutions.co.uk
Phone: 01708843640, 02034323039

All concerns will be investigated promptly and confidentially.
 

If a case is confirmed or strongly suspected, we will:

• Contact the relevant safeguarding authority and police.

• Suspend supplier contracts if necessary.

• Provide appropriate support to affected individuals.

 

9. Training and Awareness

• All staff will receive training on modern slavery and human trafficking as part of

induction and ongoing safeguarding updates.

• Managers will receive additional training on identifying risks and taking action.

• Posters and materials will be displayed in workplaces to raise awareness.

 

The Following Are indicators of Modern Slavery
Physical Appearance

• Shows signs of physical or psychological abuse, looks malnourished

or unkempt, anxious/agitated, or appearswithdrawn and neglected. They
may have untreated injuries.
Isolation

• Rarely be allowed to travel on their own, seem under the control, the

influence of others, rarely interact or appearunfamiliar with their
neighbourhood or where they work.

• Relationships which do not seem right - for example, a young teenager

appearing to be the boyfriend/girlfriend ofa much older adult.

 

Poor Living Conditions

• Be living in dirty, cramped, or overcrowded accommodation, and/or living

and working at the same address.

Restricted Freedom of Movement

• Have no identification documents, have few personal possessions, and

always wear the same clothes day in andday out. What clothes they do wear
may not be suitable for their work.

• Have little opportunity to move freely and may have had their travel

documents retained, e.g., passports.

Unusual Travel Times

• Be dropped off/collected for work regularly either very early or late at night.

• Unusual travel arrangements - children being dropped off/picked up in

private cars/taxis at unusual times and inplaces where it is not clear why
they would be there.

Reluctant to Seek Help

• Avoid eye contact, appear frightened or hesitant to talk to strangers and

fear law enforcers for many reasons,such asnot knowing who to trust or
where to get help, fear of deportation, fear of violence to them or their family.

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The Following Signs Could Indicate a Situation of Labour Exploitation:

• Individuals may show signs of psychological or physical abuse. They

might appear frightened, withdrawn orconfused.

• Workers may not have free movement and may always be accompanied.

• Individuals often lack protective equipment or suitable clothing and

have not been trained to safely fulfil therequirements of the role.

• The person may not have access to their documents, such as IDortheir

passport, as the employer hasconfiscated them.

• Individuals may not have a contract and may not be paid National Minimum

Wage or not be paid at all.

• Workers are forced to stay in accommodation provided by the 
  employer. This accommodation could be overcrowded.

• Individuals could live on site.

• Workers could be transported to and from work, potentially with multiple

people in one vehicle.

• The person might not accept money or be afraid to accept payment.

• Workers may work particularly long hours.

 

The Following Signs Could Indicate aSituation of Sexual Exploitation:

• Sex workers may appear scared orintimidated.

• The individual may be transported to and from clients.

• Individuals may be closely guarded.

• The person may be 'branded' with a tattoo indicating ownership.

• Sex workers may show signs of physical abuse, including bruising, scarring,

and cigarette burns.

• The individual may be unable to keep payments and may have restricted or

no access to their earnings.

• The person may have a limited English vocabulary, restricted to sexualized

words.

• Multiple female foreign nationals may be living at the same address.

• The person may sleep in the premises in which they work, which could indicate

a brothel is operating.

• A property might have male callers’ day and night who only stay for a shorttime.

• There may be details of sexual activity, such as cards and advertisements

found nearby.

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The Following Signs Could Indicate aSituation of Domestic Servitude:

• The individual may be held in their employer's home and forced to carry out

domestic tasks such as providingchildcare, cooking, and cleaning.

• The individual may not be able to leave the house on their own, or their

movements could be monitored.

• The person may work over normal working hours.

• The individual may not have access to their belongings, including their

ID, but also items such as their mobilephone, which can isolate them.

• The employer may be abusive, both physically and verbally

• The person may not interact often with the family they are employed by.

• The person may be deprived of their personal living space, food, water, or

medical care.

• The individual may stand out from other family members, noticeable as they

may wear poorer quality clothing.

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The Following Signs Could Indicate a Situation of Criminal Exploitation:

• A large group of adult or children beggars might be moved daily to

different locations but return to the same location every night. This could
indicate forced begging.

• An individual might be transported to or from the scene of a crime,

including shoplifting, pickpocketing or forcedbegging.

• An individual may not benefit from the money or items they have

obtained through the crimes they have beenforced to commit.

• A person may be forced to cultivate cannabis with their freedom of

movement restricted, weeded including being locked in a room. Commonly,
the individual may not be able to speak English or have a limited vocabulary.

• A vulnerable person maybe forced ormanipulated outoftheir home by

drug dealers who use the home as abase to sell drugs.

• Young people may be forced to transport and sell drugs across county borders,

which is known as County Lines

The Following Signs Could Indicate a Situation of Child Exploitation:

 

• The child may have mood swings, including being angry, upset or withdrawn.

• The child may show signs of inappropriate sexual behaviour.

• They may be dressed inappropriately for their age.

• The child may go missing at night or on weekends and may not be clear about

their whereabouts.

• They may not attend school.

• The child may have gifts, presents or expensive items which they cannot

explain.

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Who needs to publish a statement?

A commercial organisation is required to publish an annual statement if all the criteria
below apply:

• It is a ‘body corporate’ or a partnership, wherever incorporated or formed.
• It carries on a business, or part of a business, in theUK.
• It supplies goods or services.
• It has an annual turnover of £36 million or more.

Organisations are responsible for determining whether the legislation applies to them.
You may wish to seek legal advice todecide if your organisation needs to produce an
annual statement.

If Primrose Healthcare Solutions Services Limited meets the criteria,the modern slavery
statement must.

 

• Be published on the organisation’s UK website with a link in a prominent

place on the UK homepage. The emphasis on visibility is intended to
enhance reporting standards, encouraging companies to publicly
demonstratetheir commitment to addressing modern slavery.

• Be approved by the board or directors and signed by a director. This

assigns ownership to senior-level management and encourages their
proactive involvement in tackling abusive practices in business
operations.

​

Companies that do not meet these basic requirements are breaking the law.

 

• Primrose Healthcare Solutions Services Limited structure, business, and

supply chains

• Its policies in relation to slavery and human trafficking

• The due diligence processes of Primrose Healthcare Solutions Services

Limited in relation to slavery and humantrafficking in its business and
supply chains

• The parts ofits business and supply chains where there is a risk of slavery

and human trafficking taking place,and the steps that Primrose Healthcare
Solutions Services Limited has taken to assess and manage that risk.

• Its effectiveness in ensuring that slavery and human trafficking is not taking

place in its business or supply chains,measured against such performance
indicators as it considers appropriate.

• The training about slavery and human trafficking is available to Primrose

Healthcare Solutions Services Limited staff.

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The statement must be:
• Written in simple language.
• Succinct, but cover all relevant points and link to relevant
documents within Primrose Healthcare SolutionsServices Limited
• In English but may be provided in other languages that are relevant to the
supply chain.

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What else must it include?

• The statement must include either a statement of the steps Primrose

Healthcare Solutions Services Limited has takenduring the financial yearto
ensure that slavery and human trafficking is nottakingplace (in any ofits supply
chains and in any ofits own business), or that Primrose Healthcare Solutions
Services Limited has taken no such steps.

• The statement must be true, referring to actual steps undertaken or begun

and must be built upon year after yearto evolve and improve over time.

• The statement needs to be published, and any director signing the

statement needs to be satisfied that thestatement is true. This might
include carrying out a full investigation.

• Charities and educational institutions are captured by the obligation. If the

turnover is £36m, goods or services aresupplied, and it carries on business
within the UK, it is irrelevant to the purpose for which its profits are made. Both
franchisors and franchisees may be captured if they meet the turnover
thresholds.

• The statement will be published on the website of Primrose

Healthcare Solutions Services Limited and, whereappropriate, linked
through to any otherrelevantwebsites ofPrimrose Healthcare Solutions
Services Limited

• It must be obvious on the home page or clearly accessible by a drop-down

menu. Historical statements can alsobe retained online when the new
statements are published, to allow comparisons to be made and monitoring of
Primrose Healthcare Solutions Services Limited over time.

• If a parent company meets the requirements, it mustinclude in its statement

the steps taken with each of itssubsidiaries if they form part of the parent
company's supply chain or business (even if the subsidiaries themselves do
not meet all the requirements)

• A subsidiary organisation that meets the thresholds in its own right must

produce its own slavery and humantrafficking statement. However, a parent
company may produce one statementthatthe subsidiaries also use.

THIS STATEMENT REFLECTS PRIMROSE HEALTHCARE SOLUTIONS SERVICES LTD

This statement sets out the steps that Primrose Healthcare Solutions Services Limited
has taken and is continuing to take to ensure that modern slavery or human trafficking
is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking, and forced labour.
Primrose Healthcare Solutions Services Limited has a zero-tolerance approach to any
form of modern slavery and human trafficking. We are committed to acting ethically
and with integrity and transparency in all business dealings and to putting effective
systems and controls in place to safeguard against any form of modern slavery taking
place within the business or our supply chains.

We provide home care services to xxx number of people, with xx number of staff at xx
number of locations. State if you work with any partners, e.g., Local Authorities.]
Primrose Healthcare Solutions Services Limited implements its business strategy in an
ethically, socially, and environmentally responsible manner. We fully acknowledge our
responsibility to respect human rights as set out in the International Bill of Human
Rights. The IBHR informs all our policies related to the rights and freedoms of every
individual who works for us, either as a direct employee, agency worker, or indirectly
through our supply chain. We are also committed to implementing the United Nations
Guiding Principles on Business and Human Rights throughout our operations. Respect
for the dignity of the individual – and the importance of each individual’s human rights –
forms the basis of the behaviours we expect in every workplace nationally.
We will not accept any form of discrimination, harassment, or bullying, and we require
all our managers to implement policies designed to increase equality of opportunity
and inclusion for all employees, including agency workers. We have also developed and
implemented policies and processes that are intended to extend these commitments
through our supply chain.

Policies
We have several internal policies to ensure that we are conducting business ethically
and transparently. These include:

• Human Rights policy and our Ethics Policy, where we confirm that we will not

tolerate or condone the abuse of human rights within any part of our business or supply
chains and will take seriously any allegations that human rights are not properly
respected.

• The Whistleblowing Policy, aimed principally at our employees but also available

to others working in our supply chains, encourages staff to report any wrongdoing that
extends to human rights violations like Modern Slavery. All reports will be fully
investigated, and appropriate remedial actions will be taken, and we will work closely
with social care and health providers, ensuring that our policies and procedures
dovetail with local procedures and best practice.

• A robust recruitment policy, including conducting eligibility to work in the UK

checks for all employees, to safeguard.

• Employee Code of Conduct consistent with any professional codes of conduct

Direct Communication

The Company encourages members of the public or people not employed by us to
write, in confidence, to raise any concern, issue, or suspicion of modern slavery in any
part of our business.
Suppliers
We conduct due diligence on all suppliers before allowing them to become a preferred
supplier. We include an online search to ensure that organisations have never been
convicted of offences relating to modern slavery, and we include our modern slavery
policy as part of our contract with all suppliers. Suppliers are required to confirm that
no part of their business operations contradicts this policy. As part of our contract with
suppliers, they confirm to us that:

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1. They have taken steps to eradicate modern slavery within their business.

2. They hold their suppliers to account over modern slavery.

3. For UK based suppliers, they pay their employees at least the national minimum

wage/national living wage (as appropriate) and to ensure that within their supply chains,
where UK based suppliers have overseas supply chains, that their employees' pay is
consistent with their national minimum wage requirements, working conditions are
safe and fair, there is no child labour and working hours are not excessive.

 4. We may terminate the contract at any time should any instances of modern

slavery come to light.

Risk Assessments

Our supply chains include procurement of staff, consumables, facilities maintenance,
utilities, and waste management. We have conducted a risk assessment and will
ensure that we take further steps to ensure that we support the eradication of modern
slavery, that staff understand how to recognise modern slavery, and the appropriate
safeguarding reporting processes are followed should there be concerns within our
supply chains, with customers or suppliers.

Performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery is
not taking place within our business or supply chain if:
• No reports are received from employees, the public, law enforcement agencies,
or local safeguarding teams to indicate that modern slavery practices have been identified.

Safeguards
We aim to encourage openness and will support anyone who raises genuine concerns
in good faith under this policy, even if they turn out to be mistaken. We are committed
to ensuring that no one suffers any detrimental treatment as a result of reporting in
good faith their suspicion that modern slavery of whatever form is or may be taking
place in any part of our business. Detrimental treatment includes dismissal,
disciplinary action, threats, or other unfavourable treatment connected with raising a
concern. Primrose Healthcare Solutions Services Limited will accept and take seriously
concerns communicated anonymously. However, retention of anonymity does render
investigations and makes validation more difficult and can make the process less
effective. Individuals are therefore encouraged to put their names to allegations. Any
claims or allegations made that are found to be malicious or vexatious will result in
disciplinary action being taken against the individual.

Responsibility for this Statement
The ultimate responsibility for the prevention of modern slavery rests with the [insert
who at Senior Management level has responsibility] for ensuring that this policy and its
implementation comply with our legal and ethical obligations. Managers at all levels are
responsible for ensuring that those reporting to them understand and comply with this
policy and are given adequate and regular training on it and the issue of modern slavery.
Assessment of effectiveness in preventing Modern Slavery
We understand that modern slavery risk is not static and will continue our approach to
mitigating this risk. We will assess the risk via our internal auditing processes.

This statement is made according to section 54(1) of the Modern Slavery Act 2015 and
constitutes the modern slavery and human trafficking statement of Primrose
Healthcare Solutions Services Limited for the financial year ending 2025; Approved by
Director of Primrose Healthcare Solutions Services Limited has approved this
statement.

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9. Monitoring and Review
This policy will be reviewed annually and updated as necessary to reflect best practices
and changes in legislation.
Date of Last Review: [25/09/2025]
Next Review Due: [25/09/2026]
Approved By: Oluwakemi Awosika

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