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This policy sets Ndima Healthcare’s approach to anti-slavery. The policy also outlines Ndima Healthcare’s procedures to eliminate human trafficking and modern-day slavery. Ndima Healthcare recognises that anyone can be a victim of modern slavery and human trafficking. Therefore, Ndima Healthcare recognises it has a responsibility to take a robust approach to tackle modern slavery and human trafficking.


The Modern Slavery Act of 2015 simplified and unified earlier legislation about human trafficking and slavery. The Act classifies "human trafficking" and "slavery, servitude, and forced or involuntary labour" as offences. These offences include assisting someone's journey to take advantage of them while travelling or shortly after that or holding them knowingly in a position of slavery, servitude, or forced or coerced labour.


The Statement

This statement is published by Section 54 of the Modern Slavery Act 2015 Act and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulation 2015 (the “Act”). It sets out the steps taken by  Ndima Healthcare to prevent modern slavery and human trafficking in its business and supply chain.


Ndima Healthcare fully supports the Government’s objectives to eradicate modern slavery and human trafficking and recognises the significant role we can play in combatting and supporting victims. In particular, we are strongly committed to ensuring our supply chains and business activities are free from ethical and labour standards abuses.

We recognise that, being in the healthcare industry, we are exposed to risks relating to the potential violation of human rights in areas including modern slavery and human trafficking. We are conscious that such risks can arise in certain areas of the sector, particularly nursing, aged care provision, and the manufacturing of healthcare equipment. We are committed to monitoring such risks in our business and our wider supply chain and mitigating them.


Steps taken to date include:



We promote a workplace environment that is fair, open and respectful and one that protects the rights and dignity of all employees. We operate people practices, employment contracts, and collective agreements that are lawful and aligned with our Code and values.


  • We confirm the identities of all new employees, temporary workers and contractors and their right to work in the United Kingdom, and pay all our employees above the National Living Wage

  • Our Respect at Work, Grievance and Voicing your Concerns for Staff policies also give our employees a platform to raise concerns about poor working practices.

  • We use social media to raise awareness and invest in training to ensure front-line staff are aware of and able to respond to incidents of modern slavery



Our whistleblowing policy sets out our commitment to ensure people are free to question things and raise anything they are concerned about, specifically modern slavery and human trafficking. We encourage people to speak up by raising matters with Beatrice Tanyanyiwa, Director.   


Procurement and our supply chain

  • Our current due diligence process includes a modern slavery assessment.

  • When procuring goods and services, we additionally apply specific Terms and Conditions that require suppliers to comply with relevant legislation.


Review of effectiveness

We intend to take further steps to identify, assess and monitor potential risk areas in modern slavery and human trafficking, particularly in our supply chains.


In 2023/24, our anti-slavery programme will also:


  • continue to support all staff to understand and respond to modern slavery and human trafficking and the impact that every individual working in the healthcare sector can have in keeping present and potential future victims of modern slavery and human trafficking safe

  • ensure that staff have access to training on how to identify those who are victims of modern slavery and human trafficking. This training will include the latest information and will help staff develop the skills to support individuals who come into contact with health services

  • review our safeguarding policies and training programmes to ensure that Modern Slavery and human trafficking reflect potential requirements in pending reforms relating to the pre-criminal needs of people involved in human trafficking and modern slavery

  • undertake a risk assessment on transparency in the supply chain, including an overview of products, services and suppliers procured.

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