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Modern slavery & human trafficking policy

Zentar Healthcare Limited · last reviewed 5 September 2026

Policy statement

The term slavery is often associated with the 18th and 19th centuries; however, the practice continues today in one form or another in every country in the world and is becoming significantly more prevalent in the UK.

The Modern Slavery Act 2015 consolidates slavery and trafficking offences and introduces tougher penalties and sentencing rules. It ensures that the police and law enforcement agencies have the powers they need to pursue, disrupt and bring to justice those engaged in human trafficking and slavery, servitude and forced or compulsory labour. It also introduces measures to enhance the protection of victims of slavery and trafficking.

Zentar Healthcare Limited provides a permanent, executive, interim, contract and temporary recruitment service within the nursing, medical and overall healthcare market in the UK, US and the Middle East.

We oppose all forms of slavery and trafficking and are fully committed to compliance with the Modern Slavery Act 2015.

We have therefore created the following procedure to ensure that all staff, suppliers, business partners, consultants, contractors, and temporary workers understand what modern slavery is, how to recognise the common signs of it and how to report it. Staff involved in procurement are instructed on how to conduct due diligence to ensure our supply chains for core products remain slavery-free.

Scope of the policy

It is the duty of all employees, suppliers, business partners, consultants, contractors, and temporary workers to comply with this policy. All employees are made fully aware of this policy and of their duties and responsibilities under the above legislation as part of the company’s induction program. Suppliers, business partners and consultants are made aware of the policy as part of their contract with us.

Zentar Healthcare Limited has not yet reached the minimum annual turnover threshold of £36 million which requires us to communicate an annual slavery and human trafficking statement on our website and disclose what steps we have taken during the financial year to ensure our business and supply chain remains slavery-free. That said we comply with all aspects of the Modern Slavery Act 2015 to prevent the exploitation of workers within both our organisation and our supply chain.

Responsibilities

It is the direct responsibility of the Operations Director to ensure the implementation of this policy on a day-to-day basis; however, all employees have a responsibility to accept their involvement in applying it and must be familiar with the policy and ensure that it is followed by both themselves and employees, contractors and temporary workers for whom they have a responsibility.

This policy will form part of Zentar Healthcare Limited induction training and is documented in the Employee handbook which in turn forms part of each employee’s contract of employment.

Disciplinary action may be taken against any employee who acts in breach of this policy. Disciplinary action may include summary dismissal in the case of a serious breach or repeated breaches. In other cases, it may include a verbal or written warning. Such action will be taken by the Company’s disciplinary procedure. Breaches of this policy may also result in the employee responsible being held personally liable if legal action is taken about modern slavery issues. All staff have a responsibility to be vigilant, looking out for signs of modern slavery in the workplace and reporting these immediately in line with our Whistleblowing procedure.

For contractors or temporary workers, the assignment may be terminated immediately, and the contractor or temporary worker may not be offered further work until the outcome of the enquiry has been completed.

Suppliers, business partners and consultants risk termination of their contract with Zentar Healthcare Limited if found to be in breach.

What is modern slavery?

Many different characteristics distinguish slavery from other human rights violations, however only one of these needs to be present for slavery to exist. Someone is in slavery if they are:

• Forced to work – through mental or physical threats.
• Owned or controlled by an ’employer’, usually through mental or physical abuse or the threat of abuse.
• Dehumanized, treated as a commodity or bought and sold as ‘property’.
• Physically constrained or has restrictions placed on his/her freedom of movement.

Contemporary slavery takes various forms and affects people of all ages, genders and races. Common forms of Modern Slavery include:

• Forced labour – any work or service which people are forced to do against their will under threat of some form of punishment. Almost all slavery practices contain some element of forced labour. It is frequently found in labour-intensive and/or under-regulated industries such as agriculture & fishing, domestic work, construction, mining, quarrying, manufacturing, processing, packaging, prostitution & sexual exploitation, market trading and illegal activities.
• Bonded labour – a person becomes a bonded labourer when their labour is demanded as a means of repayment for a loan. The person is then tricked or trapped into working for very little or no pay and debts are often passed from generation to generation.
• Human trafficking – involves people including children being brought into a situation of exploitation through the use of violence, deception or coercion and forced to work against their will. People can be trafficked for many different forms of exploitation including forced prostitution, forced labour, forced begging, forced criminality, domestic servitude, forced marriage and even forced organ removal. When children are trafficked, no violence, deception or coercion needs to be involved: simply bringing them into exploitative conditions constitutes trafficking.
• Descent-based slavery – a situation where people are born into a ‘slave class’, caste or a group viewed as being in slavery by other members of their society. If one’s mother is in slavery, one is born into slavery.
• Child slavery – includes children who are used by others who profit from them including prostitution or pornography, forced begging and petty theft, the drug trade, forced labour (including domestic work) and forced participation in armed conflicts.
• Slavery in supply chains – many of the products we buy and use every day were made using forced labour at some point in production. This is not just about a company’s suppliers, but the suppliers of suppliers right back to the raw material.
• Forced and early marriage – covers children under the age of 18 and can be referred to as slavery if one or more of the following elements are present:
  • If the child has not genuinely given their free and informed consent to enter the marriage.
  • If the child is subjected to control and a sense of “ownership” in the marriage itself, particularly through abuse and threats, and is exploited by being forced to undertake domestic chores within the marital home or labour outside it, and/or engage in non-consensual sexual relations.
  • If the child cannot realistically leave or end the marriage, leading potentially to a lifetime of slavery.

Common signs of modern slavery

Modern Slavery is a hidden crime because it can be difficult to identify a victim. Common signs include:

Physical appearance where the person:

• Is fearful, anxious, depressed, submissive, tense, or nervous/paranoid.
• Exhibits unusually fearful or anxious behaviour.
• Appears withdrawn.
• Avoids eye contact.
• Is reluctant to seek help.
• Lacks health care/dental care.
• Appears malnourished.
• Shows signs of physical and/or sexual abuse, physical restraint, confinement, or torture.

Isolation where the person:

• Is not allowed to travel on their own.
• Rarely interacts with others.
• Is unfamiliar with their neighborhood or where they work.
• Seems under the control of others.

Lack of control where the person:

• Has few or no personal possessions.
• Is not in control of his/her own money, no financial records, or bank account.
• Is not in control of his/her identification documents (ID or passport).
• Is not allowed or able to speak for themselves (a third party may insist on being present and/or translating).
• May wear the same clothes day in and day out or clothes that are inappropriate for the work being done.

Poor living conditions which are:

• Dirty cramped environment.
• Over-crowded accommodation.
• Involve living and working at the same place.

Unusual travel times where the person:

• Maybe dropped off and collected for work regularly either very early or late at night.

Actions to reduce the risk of modern slavery

Zentar Healthcare Limited will:

• Ensure all employees, contractors and temporary workers are aware of what constitutes modern slavery and the common indicators to enable them to identify victims more easily.
• Conduct a recruitment process which is designed to identify whether prospective workers are face-to-face interviews with employees and workers which include questions designed to identify whether the prospective employee / worker is likely to be subject to any form of modern slavery.

We also:

• Conduct face-to-face checks of original right to work documentation.
• Undertake passport and right to work ID Checks
• Only pay wages into a bank account that is in the name of the worker (in individual or joint names).
• Monitor multiple occurrences of workers with the same home address or bank details.
• Run regular DBS update checks, as well as checks with relevant governing bodies etc GMC, NMC etc.
• Ensure that employees, contractors and temporary workers are advised of their rights under the company’s Ethics and Labour Standards Policy and associated legislation.
• Ensure that suppliers, customers, business partners and others who are directly linked to our business operations have received a copy of this policy and understand that we have a zero-tolerance approach to modern slavery.
• Conduct risk assessments to determine which parts of our business and which suppliers (if any) are most at risk of modern slavery or human trafficking so that our efforts can be focused on those areas
• Walk away from business or contracts that we suspect may expose us to organisations that condone or use modern slavery practices either directly or indirectly and report any supplier or partner to the appropriate law enforcement body if we suspect them of misconduct in this area.
• Conduct due diligence with formal suppliers with the aim of ensuring that the company does not purchase products where slavery or human trafficking may form part of the production process. This includes avoiding complex supply chains where such risks are increased.
• Include clauses relating to modern slavery and human trafficking in contracts with formal suppliers and require them to confirm in writing that they will comply with the company’s Purchasing & Procurement Policy and Ethics & Labour Standards Policies.
• Examine the company’s direct operations, supply chain and other business relationships in high-risk environments to identify risk factors.
• Review performance of key suppliers in terms of policies and practices regarding labour rights issues as part of the procurement process for key purchases.
• Document any identified instances of modern slavery in the business or supply chain together with details of corrective action plans and results.
• Avoid making demands of suppliers of subcontractors that may lead them to abuse human rights and ensure agreed payment terms are adhered to.
• Put in place procedures for reporting concerns over modern slavery within the company’s operations and communicate these effectively including a Whistleblowing Policy and clear grievance procedure and ensure that employees, contractors and temporary workers understand that they can report unethical conduct without fear of reprisal or retaliation.
• Follow up any reports or suspicions relating to modern slavery or human trafficking.
• Ensure compliance with associated company policies including its:
  • Purchasing & Procurement Policy.
  • Ethics & Labour Standards Policy.
  • Whistleblowing Policy.
• Provide a copy of this Modern Slavery & Human Trafficking Policy to anyone who makes a written request for it within 30 days from receipt of the request.
• Maintain corporate membership of REC and take advice from them to ensure our code of conduct/practice contains current best practice for minimising risks associated with modern slavery & human trafficking.
• Comply fully with the ETI Base Code including the April 2014 Amendment as detailed below.

The ETI base code

Zentar Healthcare Limited complies fully with the ETI Base Code:

1. Employment is freely chosen. There is no forced, bonded or involuntary prison labour and workers are not required to lodge “deposits” of their ID papers with us or our clients and are free to leave after reasonable notice.
2. No employee will be prevented from joining or forming a staff association or trade union, nor will any employee suffer any detriment as a result of joining, or failing to join, any such organisation. Representatives will not be discriminated against and will have access to carry out their functions in the workplace.
3. Working conditions are safe and hygienic and adequate provisions are taken to prevent accidents and injuries to health by minimising hazards in the workplace. In line with our Health & Safety Policy, all employees will receive health & safety induction training.
4. Child labour will not be used and Zentar Healthcare Limited will not knowingly engage with organisations that use child labour.
5. Employees will be made aware of the terms and conditions of their employment or engagement from the outset. In particular employees must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Employees must also be allowed such annual leave, sick leave, maternity / paternity leave and such other leave as is granted by legislation as a minimum. Deductions from wages as a disciplinary measure is prohibited and all disciplinary action will be recorded.
6. Working hours will not be excessive and contracted hours shall not exceed 48 hours per week unless the employee has opted out of the working time regulations. Overtime is voluntary and the total hours worked in a week shall not exceed 60 unless exceptional circumstances apply.
7. In line with our Equality, Diversity & Inclusion Policy, we do not discriminate in hiring, compensation, access to training, promotion, termination or retirement based on any protected characteristic as identified in the Equality Act 2010. All employees must be treated equally. Employees with the same experience and qualifications should receive equal pay for equal work.
8. To every extent possible regular employment will be provided.
9. No harsh or inhumane treatment is allowed including physical abuse or discipline, sexual abuse or the threat of such abuse or intimidation.

Reporting of suspected, alleged or confirmed cases of modern slavery & human trafficking

Any suspected incidence of modern slavery or human trafficking will be taken seriously and may be reported confidentially in line with the company’s Whistleblowing Policy or grievance procedure. Employees, contractors and temporary workers are required to familiarise themselves with this policy and to inform their Line Manager if:

• They suspect an employee or person acting on behalf of Zentar Healthcare Limited, supplier or person acting on behalf of a supplier is seeking to exploit another in a way which could amount to modern slavery.
• They have received an approach from a person acting on behalf of Zentar Healthcare Limited or a supplier inviting them to participate in an act which could result in an offence under the Modern Slavery Act 2015 being committed.
• They have information which leads to the rational conclusion that a person acting on behalf of Zentar Healthcare Limited or one of our suppliers is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act 2015.

Any employee, contractor or temporary worker can expect full protection when making such a disclosure and will not suffer detriment or reprisals of any type for doing so. Anyone raising a genuine concern in good faith will be protected, even if they turn out to be mistaken. Any claim or allegation found to be malicious or vexatious will however result in disciplinary action being taken against the employee.

Details of all such reports will be recorded by the company and audited at least annually.

Employees may wish to contact the Modern Slavery Helpline on 0800 0121 700. This will allow anyone who thinks they may have come across an instance of modern slavery, or indeed who may be a victim themselves, to call for more information and guidance on what to do next.

If a specific case of modern slavery is identified in the UK, it should be reported to the police immediately on 101. If potential victims are in immediate danger the standard 999 emergency number should be used.

Review

This policy will be reviewed regularly and may be altered from time to time in light of legislative changes or other prevailing circumstances.