Modern Day Slavery Statement

Introduction

This statement has been published in accordance with section 54 of the Modern Slavery Act 2015. It sets out the steps taken by HCML during the financial year 1 April 2025 to 31 March 2026 to prevent modern slavery and human trafficking in its own business operations and supply chains.

Modern slavery encompasses slavery, servitude, forced or compulsory labour, and human trafficking. HCML has a zero-tolerance approach to any form of modern slavery and is committed to acting ethically, with integrity and transparency, in all business dealings. We aim to maintain effective systems and controls to identify, assess and mitigate the risk of modern slavery occurring within our business or supply chain.

About the Organisation

HCML is a healthcare provider delivering a range of services, including health and wellbeing solutions, case management, injury rehabilitation, treatment services, occupational health, lifetime care and expert witness services to the personal injury, private medical insurance and corporate markets.

HCML employs almost 400 staff nationally.

The majority of our suppliers and service providers are based in the UK. Our supply chain includes clinical, professional, operational and business support services. We recognise that, while our direct supplier base is predominantly UK-based, modern slavery risks can still arise through labour practices, subcontracting arrangements, recruitment practices and lower-tier supply chains.

Our Policies on Slavery and Human Trafficking

HCML is aware of our responsibilities towards customers, clients, patients and employees and expect all our suppliers to adhere to the same ethical principles. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our internal policies replicate our commitment to acting ethically and with integrity in all our business relationships. Currently all awarded suppliers sign up to our terms and conditions of contract which contain a provision to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains; and that they conduct their businesses in a manner that is consistent with HCML’s anti-slavery principles.

Relevant policies

HCML operates the following policies and controls to support the identification of modern slavery risks and the prevention of slavery and human trafficking within our operations.

• Recruitment Policy – We operate a robust recruitment process, including eligibility to work in the UK checks for all directly employed staff. Agencies on approved frameworks are vetted to provide assurance that appropriate pre-employment checks have been completed for agency staff, helping to safeguard against human trafficking and individuals being forced to work against their will.
• Equality and Equal Opportunities Policy – We maintain controls to protect colleagues from poor treatment and exploitation, in line with applicable laws and regulations. These include fair terms and conditions of employment, fair pay practices, and access to training and development opportunities.
• Safeguarding Policies – We adhere to the principles set out in our safeguarding children and safeguarding adults policies. These provide guidance to colleagues on recognising and raising concerns about how colleagues, patients, clients or people receiving our services are being treated, including concerns linked to exploitation or abuse.
• Whistleblowing Policy – We operate a whistleblowing policy so colleagues can raise concerns about wrongdoing, poor practice, exploitation, or practices within our business or supply chain without fear of reprisal.
• Supplier Code of Conduct – This code explains the standards of conduct we expect from our suppliers, including ethical working practices and compliance with applicable legal and regulatory requirements.

Due Diligence and Supplier Assurance

HCML applies proportionate due diligence to suppliers and business partners based on the nature of the services provided and the level of risk presented. This includes reviewing contractual commitments, supplier assurance information and relevant governance documentation where appropriate.

During the reporting period, HCML continued to maintain supplier controls through contractual terms, supplier onboarding requirements and governance oversight. No concerns were reported to HCML through its established governance and reporting mechanisms.

Risk Assessment and Management

HCML considers the risk of modern slavery within its direct workforce to be low because colleagues are employed in the UK, supported by recruitment controls, right to work checks, HR policies, safeguarding arrangements and mechanisms for raising concerns.

Potential risk areas are more likely to arise in the wider supply chain, particularly where services involve subcontracting, agency labour, lower-paid roles or complex labour arrangements. HCML manages these risks through supplier assurance, contractual requirements, policy controls and escalation routes for concerns.

Training

Advice and training about modern slavery and human trafficking is available to colleagues through mandatory safeguarding children and adults training, safeguarding policies and procedures, safeguarding leads and induction training.

Targeted awareness and guidance will continue to be provided to colleagues in management, procurement, supplier management and other roles with responsibility for engaging or overseeing suppliers.

HCML will continue to strengthen awareness across the organisation and maintain a good understanding of the risks linked to modern slavery and human trafficking in our business and supply chain.

Performance Indicators and Effectiveness

HCML monitors the effectiveness of its approach through proportionate performance indicators and governance oversight. During the financial year ending 31 March 2026, the indicators considered included:

• Completion of relevant mandatory safeguarding training by colleagues, including awareness of exploitation and routes for raising concerns.
• Availability of internal escalation routes, including safeguarding, HR, management and whistleblowing processes.
• Continued application of supplier onboarding, contractual and assurance controls for awarded suppliers.
• No concerns received from colleagues, suppliers, clients, the public or law enforcement agencies indicating that modern slavery or human trafficking had been identified within HCML’s business or supply chain.
• Annual review of the Modern Slavery and Human Trafficking Statement as part of HCML’s governance arrangements.

For the next reporting period, HCML will continue to review supplier assurance arrangements, maintain colleague awareness through training and safeguarding governance, and consider whether additional targeted modern slavery awareness is required for colleagues involved in procurement and supplier management.

Board Approval

This statement has been reviewed as part of HCML’s annual review process and approved by HCML’s CEO, James Murray. It will be reviewed and updated annually.