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Modern slavery statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and outlines the steps taken by the Online NHS Trust to prevent modern slavery and human trafficking within our organisation and supply chains.

Policy details

Version number
1
Approved by
Trust Board
Responsible Director
Chair
Policy author
Demelza Turner
Review body
Organisational Build Steering Group
Documents to read alongside this policy
Safeguarding
Review by date
31 December 2026

Introduction

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and outlines the steps taken by the Online NHS Trust to prevent modern slavery and human trafficking within our organisation and supply chains. We are committed to upholding the highest standards of ethical conduct and transparency in all aspects of our operations.

Our organisation

The Online NHS Trust has been established to be a national provider of virtual elective care. Our services will offer an expanding range of end-to-end speciality elective care services, as a choice for all patients across England. While our clinical delivery will be digital-first, we will work with a wide range of suppliers and partners to support our infrastructure, workforce and technology.

We recognise that modern slavery can occur in many forms, including forced labour, human trafficking and exploitation. We take our responsibility seriously to ensure that these practices have no place in our organisation or supply chains.

Our commitment

We are committed to:

  • acting ethically and with integrity in all our business relationships
  • implementing and enforcing effective systems and controls to ensure modern slavery is not taking place
  • promoting awareness and vigilance among our staff and partners

Policies and governance

We have established, and continue to establish, policies and procedures that support our commitment to preventing modern slavery:

  • Procurement policy: ensures suppliers meet legal and ethical standards, including compliance with the Modern Slavery Act.

Supply chain and due diligence

Our supply chain includes providers of digital infrastructure, software development, cloud services and clinical support technologies. We assess the risk of modern slavery in our supply chain as low but remain vigilant.

We undertake due diligence through:

  • supplier vetting and contract clauses requiring compliance with the Modern Slavery Act
  • ongoing monitoring of supplier performance and ethical standards
  • engagement with NHS Supply Chain and other trusted frameworks

Training and awareness

We ensure that relevant staff have received training to raise awareness of modern slavery and human trafficking. This includes:

  • how to identify signs of exploitation
  • how to report concerns safely and appropriately
  • understanding the Trust's responsibilities under the Modern Slavery Act

Future actions

We are committed to continuous improvement and will:

  • review and update our policies
  • strengthen supplier engagement and ethical audits
  • collaborate with NHS partners to share best practice and intelligence

Approval and review

This statement has been approved by the Board of Directors of Online NHS Trust and will be reviewed annually.

Signed by the Chair, Online NHS Trust.