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Modern Slavery & Human Trafficking Policy and Procedure

Prepared to meet the expectations of the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025, PPN 009, the Modern Slavery Act 2015 and NHS Employers Check Standards.

1. Purpose

The purpose of this policy is to make sure everyone who works for, with, or through Keystone Healthcare Ltd understands what modern slavery and human trafficking are, how to spot the signs, how to report concerns immediately, and what the company will do to prevent exploitation in its own operations and in the labour supply chain that supports NHS and public sector clients.

Keystone Healthcare Ltd supplies nurses, Operating Department Practitioners (ODPs) and healthcare workers to hospitals, NHS Trusts, care homes and other commissioners across West Yorkshire and nationally. Temporary staffing is recognised by government and NHS guidance as a higher-risk labour category because of worker vulnerability, third-party recruitment, right-to-work complexity and, where relevant, international recruitment. This policy therefore treats prevention as a core compliance and safeguarding duty, not a paper exercise.

This policy covers adults. Concerns about children or young people must be handled under the Safeguarding Children and Child Protection Policy and referred to Kirklees Children’s Social Care or the police without delay.

2. Scope

This policy applies to:

  • All directors, employees, consultants and contractors of Keystone Healthcare Ltd
  • All agency workers, locums and candidates registered with Keystone (nurses, ODPs, healthcare assistants and other healthcare workers)
  • Any sub-agency, umbrella company, payroll provider, training provider or other third party used to source, pay or support workers
  • Office, IT, facilities, uniform, travel and other goods and services suppliers

It applies wherever Keystone operates, including placements with NHS Trusts, independent hospitals, care homes and other public bodies calling off RM6397 or equivalent agreements.

3. Policy statement

Modern slavery is a crime and a violation of fundamental human rights. It includes slavery, servitude, forced and compulsory labour, and human trafficking. In every case a person is deprived of their liberty so that another person can exploit them.

Keystone Healthcare Ltd has a zero-tolerance approach to modern slavery in its business and supply chains. We will act ethically and with integrity in every relationship. We will implement and enforce systems and controls so that modern slavery is not taking place in our offices, in the way we recruit and pay workers, or in the third parties we use.

We will never:

  • Charge a candidate or worker a fee for finding them work (Employment Agencies Act 1973)
  • Retain a passport, BRP, eVisa details, bank card or other original identity document as a condition of work
  • Use debt, repayment clauses that are punitive, or control of accommodation to bind a worker to us
  • Actively recruit health and social care personnel from countries on the WHO / DHSC red list, except where a government-to-government agreement expressly permits it
  • Use a labour provider that cannot evidence ethical recruitment and NHS Employers Check Standards

We will support any worker or member of staff who is a victim or potential victim of modern slavery, and we will report concerns through Kirklees safeguarding routes, the police, the Modern Slavery Helpline and, where required, the National Referral Mechanism / Duty to Notify.

4. Objectives

  • Prevent modern slavery and labour exploitation in Keystone’s own operations and labour supply chain
  • Identify victims and potential victims quickly and respond in line with national and Kirklees procedures
  • Give every worker a safe, confidential way to raise a concern without fear of reprisal
  • Meet and exceed the modern slavery expectations of RM6397, NHS commissioners and the 2025 NHS procurement regulations
  • Publish a clear annual statement even though Keystone’s turnover is below the statutory £36 million threshold
  • Measure effectiveness through training completion, audit findings, incident data and MSAT improvement actions

5. Definitions

5.1 Modern slavery

Modern slavery covers slavery, servitude, forced and compulsory labour, human trafficking and domestic servitude. Perpetrators may be organised crime groups or opportunistic individuals. Only one indicator needs to be present for a concern to be raised.

5.2 Human trafficking

Human trafficking is the recruitment, transportation, transfer, harbouring or receipt of persons, by threat, force, coercion, abduction, fraud, deception, abuse of power or vulnerability, or by payments to a person who has control over another, for the purpose of exploitation.

Human smuggling (people smuggling) is different. It is an arrangement to enter a country illegally that usually ends when the crossing is complete. Smuggling is not itself modern slavery, but a person who has been smuggled may still be a victim of trafficking or forced labour.

5.3 Exploitation relevant to a staffing agency

  • Labour exploitation / forced labour: unpaid or underpaid work, excessive hours, no contract, confiscated documents, control of bank accounts, tied accommodation, transport to work under duress.
  • Debt bondage: the worker is told they still “owe” recruitment, visa, training or travel costs after any lawful deduction has been repaid.
  • Financial exploitation: wages paid to a third party, multiple people’s benefits or wages into one account, control of a worker’s bank card.
  • Criminal exploitation: county lines, cuckooing, forced begging, forced cannabis cultivation or other offending under coercion.
  • Sexual exploitation: a worker or patient coerced into sexual activity for another person’s gain.
  • Domestic servitude: a person held in a private household and forced to work excessive hours in unacceptable conditions.

5.4 National Referral Mechanism and First Responders

The National Referral Mechanism (NRM) is the UK framework for identifying and supporting potential victims. Local authorities are First Responders. Keystone is not a First Responder. Our duty is to identify, safeguard, record and escalate immediately to the police (if there is immediate risk), Kirklees Gateway to Care, and to complete or support a Duty to Notify / NRM referral via a First Responder.

6. Roles and responsibilities

Role

Responsibilities

Managing Director

Overall accountability. Approves this policy and the annual statement. Ensures resources, training and board oversight. Signs the statement.

Compliance / Registered Manager equivalent

Day-to-day owner. Maintains the risk assessment, MSAT, worker-check audits, supplier due diligence and incident log. Escalates all concerns the same day.

Safeguarding Lead

Receives concerns, applies Making Safeguarding Personal principles, liaises with Kirklees Gateway to Care, police and clients, and records outcomes.

Recruitment consultants

Apply NHS Employers Check Standards on every candidate. Never accept original passports for “safekeeping”. Spot indicators at interview and onboarding. Report concerns immediately.

Payroll / finance

Pay workers directly into an account in their own name. Investigate shared or third-party accounts, unexplained deductions and cash-only requests.

All staff and workers

Complete training. Report concerns. Cooperate with investigations. Never ignore or “handle locally” a modern slavery indicator.

7. Procedure – reporting a concern

Victims often do not self-identify. They may present with a different issue (missed shifts, “someone else books my work”, anxiety, untreated injury, no access to their own bank account). Any indicator is enough to start this procedure.

  1. A concern is identified. This may relate to a Keystone worker, a candidate, a member of office staff, a person on a client site, or information from a Trust, care home or member of the public.
  2. If anyone is in immediate danger, call 999. Stay with the person if it is safe to do so. Do not confront a suspected perpetrator or alert them that a report is being made.
  3. The staff member must tell their line manager and the Safeguarding Lead / Compliance Lead the same working day. Out of hours, call the Managing Director and, if needed, the police or the 24-hour Modern Slavery Helpline 08000 121 700.
  4. The Safeguarding Lead contacts Kirklees Gateway to Care on 01484 414933 (24 hours) and follows the Kirklees modern slavery referral pathway. Email: [email protected]. Postal: Gateway to Care, PO Box 1720, Huddersfield, HD1 9EL.
  5. Where the person is on an NHS or care-home placement, the client’s safeguarding team and the booking manager are informed the same day, unless doing so would increase risk to the victim.
  6. If the concern involves a child, refer immediately to Kirklees Children’s Social Care Duty and Advice and the police. Do not wait for internal discussion.
  7. A First Responder (usually the local authority or police) is asked to submit an NRM referral where the adult consents, or a Duty to Notify where they do not. Keystone will provide all information it holds to support that referral.
  8. The incident is logged on Keystone’s safeguarding / modern slavery register. Lessons are reviewed at the next management meeting. Where the worker was supplied into a regulated service, the client remains responsible for any CQC notification; Keystone will cooperate fully.
  9. Whistleblowers and reporters are protected under Keystone’s Whistleblowing Policy. Detrimental treatment for raising a genuine concern is a disciplinary matter.

8. Safer recruitment and worker compliance

Every worker supplied by Keystone is subject to the NHS Employers Employment Check Standards before they work, and checks are kept in date for the life of the assignment:

  • Identity check, including photographic ID verified in person or via an approved Digital Verification Service Provider
  • Right to work check in line with Home Office employer guidance and the NHS Right to Work Checks Standard, including share-code / eVisa checks where applicable
  • Professional registration and qualification check (NMC, HCPC or other register) including alerts and restrictions
  • Employment history and references covering the required period
  • DBS / criminal records check at the correct level, with Update Service where used
  • Occupational health clearance appropriate to the role

These checks do more than satisfy a framework audit. They reduce the chance that Keystone employs or supplies a person who is being controlled by someone else, working without lawful status, or whose documents are being used by a third party.

Additional anti-slavery controls at onboarding:

  • The candidate is interviewed alone. A third party is not allowed to answer for them or sit in as a matter of course.
  • Original passports and BRPs are viewed and copied, then returned immediately. Keystone never stores original identity documents.
  • Bank details must be in the worker’s own name. Shared accounts trigger enhanced due diligence.
  • The worker is given this policy summary, the Modern Slavery Helpline number and Keystone’s confidential reporting route in writing.
  • Pay, hours, deductions and assignment terms are explained in plain English. No recruitment fee is charged.
  • Consultants are trained to notice coaching, identical addresses for unrelated workers, one person controlling several candidate phones, and last-minute document substitution.

9. International recruitment

Where Keystone sources or places internationally trained nurses, ODPs or healthcare workers, we will comply with the DHSC Code of Practice for the International Recruitment of Health and Social Care Personnel (March 2025) and seek inclusion on the NHS Employers Ethical Recruiters List where applicable.

  • No active recruitment from WHO / DHSC red-list countries unless a government-to-government agreement allows it
  • No fees charged to the individual for finding work in the UK
  • Any repayment of genuinely incurred, itemised costs must be fair, lawful and never used to trap a worker in a contract
  • Workers keep their own documents, phones and bank accounts
  • Pastoral support and a named Keystone contact are provided so a worker can raise exploitation concerns without going through an overseas agent

Keystone will not use an overseas agent or UK sub-recruiter that cannot evidence ethical practice. Any allegation of unethical international recruitment is treated as a modern slavery / safeguarding concern.

10. Third parties, sub-agencies and supply chain

Keystone prefers to supply workers it has itself recruited and checked. Where a third-party agency, umbrella or payroll provider is used, Keystone will only work with organisations that:

  • Confirm in writing that they apply NHS Employers Check Standards and Home Office right-to-work rules
  • Do not charge work-seekers for finding work
  • Pay at least National Minimum Wage / National Living Wage and, for NHS assignments, the applicable framework pay arrangements
  • Accept Keystone’s modern slavery clause and the right to audit
  • Have not been convicted of modern slavery, trafficking or related labour-market offences

Contracts will allow Keystone to terminate immediately if modern slavery is identified or reasonably suspected and not remedied.

11. Training

All office staff complete modern slavery and safeguarding training at induction and at least annually. Recruitment consultants and the Safeguarding Lead complete enhanced training covering labour exploitation in staffing, international recruitment risks, indicators at interview, and the Kirklees pathway.

Agency workers receive a plain-English briefing in the handbook and at compliance induction covering: what modern slavery is, how to report it, the Helpline 08000 121 700, and that Keystone will never punish a genuine report.

Recommended sources include e-LfH Identifying and Supporting Victims of Modern Slavery, Home Office awareness materials, Unseen guidance, and Government Commercial College content on tackling modern slavery in supply chains.

12. Support for victims who work for or through Keystone

If a Keystone worker or employee is a potential victim we will:

  • Put their safety first and follow the reporting procedure above
  • Not share information with a suspected controller, family member or “agent”
  • Protect pay already earned and help them access their own bank account
  • Offer to pause or change assignments if remaining in post increases risk
  • Signpost the Salvation Army Victim Care Contract, Unseen, the Modern Slavery Helpline and local Kirklees support
  • Protect them from detriment for reporting

13. Whistleblowing

Staff and workers may report through their manager, the Safeguarding Lead, the Managing Director, or confidentially in writing to the registered office. Reports may be anonymous, although named reports are easier to investigate. Malicious or vexatious allegations will be handled under the disciplinary procedure. Genuine mistakes will not be punished.

External routes include the Modern Slavery Helpline 08000 121 700, Crimestoppers 0800 555 111, Kirklees Gateway to Care 01484 414933, the police 101 or 999, and Protect (whistleblowing charity).

14. Record keeping, audit and review

Keystone will keep a modern slavery risk register, an incident log, training records, supplier due-diligence files and evidence of NHS Employers checks. The risk assessment in Part B is reviewed at least annually and after any incident, framework audit or change in operating model (for example a new international corridor or a new sub-agency).

Effectiveness is reviewed by the Managing Director using the KPIs in Part B. This policy is reviewed every 12 months or sooner if law or NHS guidance changes.