Modern Slavery

Date last updated: 28/04/2025

This policy is made pursuant to the Modern Slavery Act 2015 and sets out the steps that HG Mind Works Ltd (“HG Mind Works”) 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.

HG Mind Works has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically, with integrity and transparency, in all company dealings to safeguard against such practices.

What is slavery?

This policy and the Modern Slavery Act 2015 cover four activities:

• Slavery: Exercising powers of ownership over a person
• Servitude: Being forced to provide services through coercion
• Forced or compulsory labour: Work or services exacted under threat, not offered voluntarily
• Human trafficking: Arranging or facilitating the travel of another person with a view to exploitation

How is it relevant to us?

Modern slavery is a complex crime, and tackling it requires vigilance from all of us. At first glance, it may seem irrelevant to our business, but it is not. Preventing exploitation and protecting our workforce and reputation are fundamental to good business practice.

The Modern Slavery Act 2015 highlights the role businesses must play. Therefore, we focus particularly on:

• Our clients and candidates
• Our suppliers
• Any outsourced activities, particularly in jurisdictions without adequate safeguards
• Cleaning and support staff
• Corporate hospitality

Responsibilities

Everyone at HG Mind Works, from directors to employees, has a responsibility to ensure that our workforce is safeguarded, treated fairly, and with dignity. Turning a blind eye is not an option.

We will:

• Maintain clear policies and procedures to prevent exploitation and human trafficking
• Ensure transparency in our recruitment policy
• Vet suppliers thoroughly
• Check our clients and candidates
• Lead by example by conducting appropriate checks
• Maintain an open grievance process
• Raise awareness internally about the welfare of our people
• Make a clear public statement of our commitment to ethical business practices

Directors

Directors will:

• Listen and be approachable to employees
• Respond appropriately to any concerns raised
• Remain alert to signs of slavery (see Identifying slavery)
• Raise employee awareness through discussion and training
• Use professional judgement to assess potential risk situations

Employees

All employees have a duty to:

• Stay alert to signs of slavery and exploitation
• Report any suspicions immediately following our reporting procedures
• Suggest improvements to help us better prevent exploitation

The Risks

Key risk areas for HG Mind Works include:

• Engaging employees
• Recruiting clinicians for client organisations

These risks are managed through the procedures set out in this policy.

Our Procedures

Anti-slavery statement

We state clearly that we take our responsibilities to employees, suppliers, clients, and candidates seriously.

We are a healthcare insourcing provider, at the heart of employment relationships, and we recognise our duty to prevent slavery and trafficking.

Supply chains

We thoroughly vet supply chains to minimise the risk of slavery and human trafficking. We make it clear to suppliers that we do not tolerate exploitation, and we include anti-slavery clauses where possible in supplier contracts.

We track our supply chains carefully to ensure transparency.

Recruitment

For clients and candidates:
Our recruitment team only uses reputable, approved recruitment agencies. We check each agency thoroughly, reviewing:

• Background
• Reputation
• Compliance with work eligibility requirements (e.g. visas)

Approved agencies are reviewed at least annually.

Internal recruitment:
We ensure all employees:

• Have a written contract of employment
• Have not paid fees to obtain work
• Are legally allowed to work in the UK

We monitor addresses for signs of exploitation and provide employees with clear information about their rights, including sick pay, holiday pay and statutory benefits.

If exploitation is suspected, it will be reported immediately.

Identifying slavery

Warning signs of potential exploitation may include:

• Lack of personal identification documents
• Being instructed or controlled by someone else
• Others speaking on their behalf
• Being dropped off and collected from work
• Withdrawn or frightened behaviour
• Lack of contact with friends or family
• Limited social interaction

If in doubt, always report concerns. A combination of these signs may indicate exploitation.

Reporting slavery

If you believe someone is in immediate danger, dial 999. Otherwise, concerns should be discussed confidentially with a Director who will decide the best course of action.

Some victims may be fearful or reluctant to seek help, so sensitivity is crucial.

Training

We provide training to all staff involved in managing recruitment, clients, candidates, and supply chains to ensure they can identify and respond to potential risks.

Monitoring our procedures

This policy is reviewed at least annually. We will update it as necessary in line with changes to legislation or company processes. Employees will be trained on any changes made.