Modern Slavery and Human Trafficking Statement


eMed Healthcare UK, Limited

Financial Year Ending 31 January 2026

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 ("MSA") and constitutes the Modern Slavery and Human Trafficking Statement of eMed Healthcare UK, Limited ("eMed") for the financial year ending 31 January 2026. It applies to all individuals and entities working on behalf of eMed.

Modern slavery is a grave violation of fundamental human rights. It encompasses forced labour, debt bondage, human trafficking, and other forms of exploitation in which individuals are compelled to work against their will. We unequivocally condemn modern slavery in all its forms and are committed to ensuring it has no place in our business or supply chain.


1. Our Organisation and Structure

eMed provides digital clinical and chronic healthcare management services through associated companies within the eMed group (operating in both the UK and US).  We also deliver a range of technology-led healthcare products. We work in partnership with one of the largest GP practices in the United Kingdom.

eMed’s workforce is primarily composed of professionals and support staff. eMed’s operations are UK-based, which we recognise represents a relatively lower risk profile for modern slavery. However, we acknowledge that risks may arise within our technology supply chain, staffing agencies, and indirect suppliers, and we take these seriously.


2. Our Policies

We maintain a suite of policies that underpin our commitment to combating modern slavery. Key among these is our Code of Ethics and Conduct, which contains an explicit Anti-Slavery provision. This provision sets out our zero-tolerance approach and establishes the standards we require of all employees and business partners.

Our relevant policies include:

  Code of Ethics and Conduct (incorporating Anti-Slavery provisions)

  Whistleblowing Policy

  UK Recruitment and Selection Policy

  Supplier Onboarding Due Diligence Checklist

These policies are reviewed on a regular basis and updated as necessary to reflect changes in legislation, best practice, and the evolving risk landscape.


3. Due Diligence Processes

We take a risk-based approach to due diligence across our operations and supply chain. During the reporting period, we undertook the following:

  Supplier onboarding: For any new suppliers over the designated threshold we completed Supplier Onboarding Due Diligence Checklists which contained specific queries relating to whether the potential supplier had their own internal anti-slavery and human rights provisions.

  Recruitment practices: We engage only with reputable, vetted staffing agencies who verify that all workers have the legal right to work in the UK.

  Whistleblowing channel: We maintain a confidential reporting channel through which employees can raise concerns about modern slavery or any other ethical issue.


4. Risk Assessment and Management

During the reporting period, we assessed the areas of our business and supply chain most susceptible to the risk of modern slavery. Our assessment considered the nature of our workforce, the geographies in which we and our suppliers operate, and the types of goods and services we procure.

Key risk areas identified:

Risk Area

Risk Level

Mitigation

Technology supply chain (software vendors, data processors)

Low

Supplier questionnaires; contractual clauses if necessary; periodic review

Staffing and recruitment agencies

Low

Agency vetting; right-to-work checks; Code of Conduct sign-off

Facilities and cleaning services

Low–Medium

Preferred supplier list; site visit reviews

Direct UK healthcare workforce

Low

Employment law compliance; HR policy framework

 


5. Training and Awareness

We are committed to ensuring that relevant staff have the knowledge and skills to recognise and respond to modern slavery risks. During the reporting period:

  All new employees receive information on our Code of Ethics and Conduct, including our anti-slavery provisions, as part of their induction programme.

  All employees are made aware of our confidential whistleblowing channel and their right to report concerns without fear of retaliation.

In the coming year, we plan to formalise and expand a training programme for Modern Slavery awareness in the procurement and HR functions and track completion rates across them.


6. Performance and Effectiveness

We monitor the effectiveness of our approach through the following indicators:

  Number of modern slavery concerns raised via our whistleblowing channel: 0 in the current reporting period.

  Percentage of new suppliers who have signed our Supplier Code of Conduct: to be reported from the next period as tracking is established.

  Completion of anti-slavery induction training: all new starters who deal in procurement of HR onboarded during the reporting period.

We recognise that our measurement framework is at an early stage of maturity. In the next reporting period we hope to establish more granular KPIs and track improvement over time.


7. Looking Ahead

In the next reporting period we are committed to the following improvements:

  Conducting a formal, documented risk assessment of our full supplier base, prioritising higher-risk categories.

  Introducing a Supplier Code of Conduct to provide to new Suppliers.

  Engaging directly with our most significant suppliers to share our Supplier Code of Conduct Modern Slavery Policy and seek their own compliance commitments.

This statement was approved by the Board of Directors of eMed Healthcare UK, Limited on 30 June 2026.

 

Note: This statement will be published on the company website and submitted to the Government's Modern Slavery Statement Registry in accordance with the MSA 2015.