Current policies and initiatives
We fully support the Government’s objectives to eradicate modern slavery and human trafficking. We are strongly committed to making sure our supply chains and business activities are free from ethical and labour standards abuses.
People
Our People policies are equality-impact assessed. They provide processes and procedures to make sure that our colleagues are always treated fairly. We:
- confirm the identities of all new colleagues and their right to legally work in the UK
- comply with the latest legislation on pay and employment terms and conditions, meaning we pay all colleagues at least the National Living Wage
- have employment policies and procedures that make sure we comply with the latest employment legislation, and provide guidance and advice to colleagues and managers
- are committed to creating and ensuring a non-discriminatory and respectful working environment for our colleagues, in line with our corporate social responsibilities
- have a set of values and behaviours that all staff are expected to comply with – all candidates are expected to demonstrate these attributes as part of the recruitment selection process
- have our Equality, Diversity and Inclusion, Solving Problems at Work, Freedom to Speak Up policies which provide a platform for colleagues to raise concerns about poor working practices or concerns about the working environment or their wellbeing
- regularly review and track progress on promoting and supporting diversity and inclusion, both as an employer and service provider
- monitor trends in our Workforce data and use Equality Impact Assessments (EIA) to inform the development of people processes and the services we provide
- publish Gender Pay Gap and other workforce and pay equality data
- require all colleagues to do mandatory diversity and inclusion training and the organisation-wide Corporate Governance training includes a section on identifying risks of Modern Slavery and Human Trafficking
- ensure our management team have all undertaken dedicated Modern Slavery training
- require all colleagues involved in procurement and commercial activities to complete CIPS Ethical Procurement and Supply training annually
Modern slavery related resources are accessible to all colleagues on the NHSBSA intranet, including the following topics:
- What is Modern Slavery?
- Where you may come across risk of modern slavery in your day-to-day lives.
- What you should do if you become aware of a modern slavery risk.
- Tackling Modern Slavery in our supply chain.
- Links to external Modern Slavery training.
NHSBSA Freedom to Speak Up policy
Our Freedom to Speak Up – Raising Concerns (Whistleblowing) policy applies to anyone who works, or has worked, for us and any organisation that provides NHSBSA services. This includes agency and temporary workers, students, and volunteers.
The policy provides a platform to raise concerns for further investigation and offers support to anyone raising concerns. The policy promotes an open, honest, and supportive culture.
We are committed to ensuring that the suppliers who we contract with either embed the principles of our 'Freedom to Speak Up' policy in their own policies and procedures or enable the utilisation of reporting mechanisms contained within NHSBSA’s policy, so their employees have suitable support to raise any modern slavery and human trafficking concerns that relate to delivery of NHSBSA services. The NHSBSA policy is included on our external webpage in an effort to promote it to suppliers.
Procurement and our supply chain
We continue to develop and enhance steps to identify, prevent and mitigate risks of modern slavery in our procurement and supply chains, ensuring compliance with the Procurement Policy Note (PPN) 009: ‘Tackling Modern Slavery in Government Supply Chains’ (as updated) and the PPN Action Notes 05/19 and 02/23.
We will be adopting The National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 (2025 Regulations) and associated NHS England (NHSE) guidance into our existing policies, processes, training and materials with effect from 17 May 2026, when the 2025 Regulations come into force.
The Anti-Slavery Risk Tiering Tool (ARTT) will be used by Commercial Services (replacing use of our own risk assessment tool which was developed internally) to assess the risk of modern slavery during procurement activities and within supply chains and existing contracts, in accordance with the 2025 Regulations and NHSE guidance.
Training on use of ARTT, the 2025 Regulations and associated NHSE guidance and the reasonable steps required to be followed, dependent upon risk level and proportionality, will be provided to all colleagues involved in procurement and commercial activities.
We achieved the CIPS Corporate Ethics Mark for the fifth year running on 17 February 2026, in recognition of:
- taking proactive steps to safeguard against unethical conduct and business practices in procurement and supply management
- making sure colleagues are trained in how to ethically select and manage suppliers
- adopting ethical values and procurement strategies on sourcing and ongoing management of suppliers
- ensuring a safe environment in which unethical practices can be reported and remedial actions can be agreed
- signing a Statement of Commitment to these values
Colleagues involved in procurement and commercial activities must do CIPS Ethical Procurement and Supply training annually. This helps colleagues, in relation to both existing contracts and new procurement activities, to identify and manage modern slavery risks and to take action when victims of modern slavery are identified.
Our procurement approach is focused on generating a modern slavery risk assessment at the earliest opportunity to allow us to proactively and proportionately design all procurement activity with the aim of eliminating risk or, where this is not possible, accommodating risk mitigation and management measures in supplier contractual obligations.
We assess suppliers to determine whether they should be excluded from the procurement process in accordance with the Procurement Act 2023 and our procurement process includes a mandatory exclusion question about complying with Section 54 of the Modern Slavery Act 2015. We apply proportionate quality criteria to mitigate the risk of price-focused competition and, where appropriate based upon risk level and nature of the supplier base and procurement activity, require suppliers to undertake due diligence so we can review prospective suppliers’ working practices, policies, procedures and supply chains.
Where procurements are deemed to be high or medium risk, enhanced activities will be undertaken which may include:
- pre-market engagement activities to understand how supply chains respond to modern slavery incidents and risks and the use of industry standards to address modern slavery
- inclusion of identified risks, industry specific modern slavery standards and due diligence activities which we expect suppliers to engage with in tender documentation
- highlighting to suppliers the contract clauses we intend to apply which relate to modern slavery risk mitigation and monitoring
- making completion of Modern Slavery Assessment Tool (MSAT) a condition of participation for high risk procurements and a contractual obligation within three months of contract award for medium risk procurements
- requiring suppliers to provide specific self-declarations for each member of their supply chain in relation to compliance with legislation, adoption of processes and procedures to mitigate and continue to monitor risk
In line with PPN 06/20 and PPN 002, we apply a minimum of 10% of the evaluation criteria to Social Value for all contract opportunities with a value of £10,000 and above and use this to address modern slavery risks. This may include tender evaluation questions centred around a supplier’s ability to tackle modern slavery, approach to diversity and inclusion, employment standards, and ethical leadership. We make sure that any Social Value commitment made by successful suppliers are then reflected in the contract terms.
Our standard contracts for the supply of services contain terms regarding Modern Slavery Act compliance principles. These are reviewed during our due diligence and assurance process. We also use Government framework agreements, including the Crown Commercial Service frameworks, which contain these provisions. The contracts set out the behaviours expected throughout procurement and supply chain relationships.
Use of risk assessment tools and MSAT reporting helps us to develop outcome focused Key Performance Indicators (KPIs) to be incorporated into contracts to measure progress in a supplier’s ability to identify, prevent, mitigate and respond more effectively to modern slavery risks on a continued basis.
Contract Management
Our previous baseline standard was to require all 'Gold' contract suppliers (by their nature those contracts most critical to our organisation) to complete MSAT annually. In light of the 2025 Regulations coming into force, we will reposition our baseline for completion of MSAT during the contract term based upon the level of modern slavery risk, as determined by risk assessment, with suppliers under high-risk contracts being requested to complete MSAT annually.
For other contract risk levels, actions required during the contract term will be proportionately driven by the outcome of the risk assessments undertaken pre and post procurement and incrementally during the contract term.
We have developed standard clauses and KPIs to be incorporated into contracts with Gold and high-risk contracts. For example, in high-risk contracts we make it an obligation of suppliers to undertake supply chain mapping, flow down anti-modern slavery and human trafficking provisions to subcontractors and put in place auditable mitigation measures, as appropriate.
We encourage suppliers to be transparent in reporting modern slavery risks and incidents within their supply chain via supplier engagement and contract management channels and work with suppliers to reassess risk levels and implement improvement measures.
Code of Conduct for Suppliers
We expect our suppliers to adhere to the same ethical principles and support fair, open and ethical practices. Their obligations are set out in our Supplier Code of Conduct in relation to procurement and supply chain and Code of Conduct for Suppliers.
These documents state that all suppliers must prohibit the use of any forced, bonded, or compulsory labour. They must not engage in any practice which is inconsistent with the rights stated in the Convention on the Rights of the Child. Any young workers must be protected from any work which is hazardous or may compromise their health, wellbeing, or education. Where sub-contractors are used, we expect our suppliers to have their own processes and policies in place to ensure that appropriate safeguards are in place to prevent modern slavery.
We expect all suppliers to follow all relevant legislation relating to:
- discrimination
- recruitment
- employment
- working hours
- health and safety
- operating a safe and healthy workplace
Effectiveness and continuous improvement
We are committed to reviewing the effectiveness of the initiatives and measures in place to identify and mitigate the risks of modern slavery and human trafficking. This will:
- ensure continuous improvement
- ensure compliance with legislation, guidance and best practices
- make us more resilient to modern slavery and human trafficking
In 2026/27, we will focus on enhancing our modern slavery programme and initiatives by:
- adopting The National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 and associated NHSE guidance
- providing training to all commercial colleagues on the use of ARTT and the latest legislation and guidance
- repositioning our baseline standard for supplier completion of MSAT reporting during contract terms based upon the level of modern slavery risk as determined by risk assessment, in accordance with the 2025 Regulations
- continuing to encourage suppliers to collaborate in the identification, reporting, mitigation and management of modern slavery risk and incidents in supply chains via supplier engagement and contract management channels
- continuing to invest effort in securing CIPS Ethics Kitemark for Commercial Services team
Adoption of the statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and applies to NHSBSA. The Board approved this statement at its meeting on 14 May 2026.
Last updated 2 June 2026.