Modern Slavery Policy

PHL Group is a healthcare company based in the United Kingdom. It provides health services across the British Isles. This statement outlines the actions of PHL Group to recognise and mitigate any potential modern-day slavery and human trafficking risks related to its own business practices and its supply chains. This statement relates to actions and activities during the financial year from October 2023 to September 2024.

As part of the healthcare sector, PHL Group recognises that we have a responsibility to take a robust approach to prevent modern-day slavery and human trafficking. This statement sets out PHL Group’s actions to understand all potential modern risks related to its business to ensure that there is no modern-day slavery or human trafficking in its business or supply chains.

Organisational Structure and Supply Chain

PHL Group provide a variety of healthcare services, including:

  • Integrated Urgent Care,
  • Primary Care Services
  • ADHD
  • Insourcing
  • Forensic Healthcare
  • Private Health Services
  • Urgent Treatment Centres.

Countries of Operation and Supply

 We currently operate in the following regions:

  • England
  • Scotland
  • Channel Islands
  • Republic of Ireland
  • Isle of Man

Supply Chain Overview

Our supply chain consists mainly of UK-based providers, including suppliers of medical equipment, medical consumables and IT services.  We also rely on external contractors for facilities management and utilities. Additionally, our clinical staffing agencies that support the delivery of our services are UK-based. 

Policies Concerning Slavery and Human Trafficking

PHL Group is committed to preventing modern-day slavery and trafficking throughout the business.  This is embedded in our internal policies and procedures.

The following policies set PHL Group’s standards:

  • Safeguarding Adults
  • Safeguarding Children & Young People
  • Freedom to Speak Up and Raise Concerns
  • Employee Code of Conduct 
  • Recruitment Policy
  • Whistleblowing
  • Modern Day Slavery Policy and Human Trafficking

These policies are reviewed regularly and approved by senior leadership. Relevant staff are made aware of the policies. Breaches of these policies are subject to escalation and disciplinary action or contract termination.

Due Diligence and Risk assessment

At PHL Group, staff undergo, right-to-work checks in the UK and follow Safer Recruitment Guidelines.

All new suppliers and contractors are subject to a risk assessment, which evaluates their stance on modern-day slavery and human trafficking within their business practices. We maintain an approved list of suppliers and contractors, which is reviewed regularly.

Training

All members of staff undergo statutory and mandatory training which includes safeguarding adults, children and young people which also covers modern-day slavery and human trafficking. We aim for all staff to have completed their mandatory training relating to modern day slavery and tracking, with a compliance level of 97% or over. This is reviewed monthly.

Managers within the business undergo Safer Recruitment training and they are responsible for auditing their recruitment practices and ensuring they align with anti-slavery and human trafficking standards.  

Monitoring Performance

PHL Group has key performance indicators   to measure how effective they are in ensuring that modern-day slavery and trafficking is not taking place in the business or within its supply chains

  • Monitoring training compliance of statutory and mandatory training in relation to modern-day slavery and trafficking through our own training records
  • Monitoring suppliers through risk assessments.

Board of Directors Approval

This statement has been approved by the PHL Group board on the 23rd of June 2025