Modern slavery act annual statement

Slavery and Human Trafficking Statement 2025/26

Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and
sets out the steps that North Tees and Hartlepool NHS Foundation Trust and its
subsidiary companies: North Tees and Hartlepool Solutions Limited Liability
Partnership (NTH Solutions LLP) and Optimus Health Limited have taken, and are
continuing to take, to make sure that modern slavery or human trafficking is not taking
place within our business, subsidiary companies or supply chain during the year
ending 31 March 2026.

Due to the scope of our business, North Tees and Hartlepool NHS Foundation Trust
recognises that it may be at risk of modern slavery, which encompasses slavery,
servitude, human trafficking and forced labour. The Trust has a zero tolerance
approach to any form of modern slavery. We are committed to acting ethically and
with integrity and transparency in all business dealings and to putting effective systems
and controls in place to safeguard against any form of modern slavery taking place
within the business or our supply chain.

About the organisation

North Tees and Hartlepool NHS Foundation Trust provides integrated hospital and
community health services to a population of around 400,000 people in Stockton-onTees, Hartlepool and East Durham, including Sedgefield, Peterlee and Easington.
Care is delivered from two main acute hospital sites, the University Hospital of
Hartlepool and the University Hospital of North Tees in Stockton-on-Tees and a
number of community facilities across the area including Peterlee Community Hospital
and the One Life Centre, Hartlepool. The Trust provides bowel and breast screening
services, as well as community dental services to a wider population in Teesside and
Durham and employs approximately 5,500 medical, nursing, allied health
professionals, clinical and non-clinical support staff with a total annual turnover of
around £365 million.

The strategic objectives of the organisation are:

Putting our population first
Valuing People
Transforming our services
Health and Wellbeing

The Trust’s Commitment

The Trust supports and is aware of its responsibilities towards patients, service users,
employees and the local community and expects all suppliers to the Trust to adhere
to the same ethical principles.

We have internal policies and procedures in place that
assess supplier risk in relation to the potential for modern slavery or human trafficking.

We have zero tolerance for slavery and human trafficking and are fully aware of our
responsibilities towards our service users, employees and local communities. We
expect all the companies we do business with to share the same ethical values.

We also have an impartial Freedom to Speak up Guardian who supports staff to raise
any concerns.

Due Diligence

We are committed to ensuring that:

TThere is no modern slavery or human trafficking in our supply chains or in anypart of our business and this includes our subsidiaries NTH Solutions LLP and Optimus Health Limited;
Employment with the Trust and our suppliers is entirely voluntary;
Our workplaces, and those of our subsidiaries and suppliers, are safe, healthy and free from discrimination or harassment based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sex or sexual orientation, or any other characteristic that is protected by law;
Corruption, in all its forms including extortion and bribery is prohibited;
We have a number of policies which support us in conducting business in an
ethical manner, including:
- Recruitment and Selection Policy
- Equal Opportunities and Diversity Policy
- Adult Safeguarding Policy
- Safeguarding Children Policy
- Freedom to Speak Up: Raising Concerns (Whistleblowing) Policy
- Standards of Business Conduct Policy
- Procurement Policy
- Resolution Policy
- Counter fraud, Bribery and Corruption Policy

All policies are reviewed to ensure they are working effectively every 3 years or earlier
if relevant laws change or new evidence or guidance becomes available and they are
available on the Trust’s website: www.nth.nhs.uk

To identify and mitigate the risks of modern slavery and human trafficking in our own
business and our supply chain, the Trust and its subsidiary companies operates and
adheres to a robust recruitment process including compliance with the National NHS
Employment Checks / Standards (this includes employees UK address, right to work
in the UK and suitable references) and employ agency staff (where appropriate) from
agencies on approved frameworks so that we are assured that pre-employment
clearance has been obtained to safeguard against human trafficking or individuals
being forced to work against their will. If there is not an available worker from a
framework agency, this is escalated to senior managers and local pre-employment
checks, including the right to work in the UK, are sought

We adhere to the principles inherent within both our safeguarding children and adult’s
policies. These provide clear guidance so that our employees are clear on how to raise
safeguarding concerns, and by ensuring representation via the safeguarding team, on
the Modern Slavery Network and the Vulnerable, Exploited, Missing, Trafficked
strategic and operational groups, we provide a level of compliance with all respective
laws and regulations. These include provision of fair pay rates, fair terms and
conditions of employment and access to training and development opportunities.

Our purchasing and procurement is governed by the new Procurement Act 2023, the
NHS ‘Supplier Code of Conduct’ and standard NHS Terms & Conditions. The
Procurement Act, which came into force in February 2025, strengthens the approach
to tackle modern slavery in public procurement by introducing mandatory exclusion
grounds and broader discretionary grounds for excluding suppliers. This means for
suppliers found to be involved in modern slavery practices or connected to individuals
convicted of such offences are more easily excluded from bidding on public contracts.

High value contracts are effectively managed and relationships built with suppliers
through frameworks, which have been negotiated under the NHS Standard Terms and
Conditions of Contract with anti-slavery and human trafficking policies and processes
in place. All of our suppliers must comply with the provisions of the UK Modern Slavery
Act (2015).

The Trust upholds professional codes of conduct and practice relating to procurement
and supply, including through our Procurement Team’s membership of the Chartered
Institute of Procurement and Supply.

Training

Advice and training about modern slavery and human trafficking, including how to
identify and respond to concerns and how to report suspected cases of modern
slavery, is available to staff through our mandatory safeguarding children and adults
training programmes, our safeguarding policies and procedures, and our safeguarding
leads.

We also provide additional, targeted training for members of staff who are likely to
identify modern slavery concerns in the course of their work. If required, bespoke
training is provided to teams who identify a need for further information and support.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery
and/or human trafficking is not taking place within our business or supply chain if: no
reports are received from our staff, the public or law enforcement agencies to indicate
that modern slavery practices have been identified.

The Trust reviews its Modern Slavery and Human Trafficking Statement on an annual
basis and presents it at the Board of Directors meeting in Public. This demonstrates a
public commitment, ensures visibility and encourages reporting standards.