This is a ‘group statement’ for the NHS in England. NHS organisations are strongly encouraged to demonstrate their commitment to eradicating modern slavery by publicly referring to this NHS modern slavery statement and aligning to the actions within. This statement covers the actions taken by NHS England to support the wider NHS to address the risk of modern slavery in the health service and points to actions best delivered nationally or locally. 

1. Organisational structure and supply chains

NHS England leads the NHS in England to deliver high-quality services for all. We do this by ensuring that the healthcare workforce has the right numbers, skills, values and behaviours to support the delivery of excellent healthcare and health improvement to patients and the public.

We share out more than £100 billion in funds each year and hold organisations to account for spending this money efficiently and effectively for patients and for the taxpayer. We work with the wider NHS and our partners to optimise the use of digital technology, research and innovation, and to deliver value for money and increased productivity and efficiency.

Staff and patients rely on NHS commercial teams to buy the goods and services they need, making sure vital supplies are delivered to the NHS without disruption, so that frontline staff can focus on providing world-class patient care.

The scale of NHS commercial activity is significant, with around 4,000 commercial, procurement and supply management professionals spending c.£30 billion across c.80,000 suppliers, including medical goods and services, office supplies, cleaning, catering and transport services. NHS England’s Central Commercial Function helps and supports Integrated Care Boards (ICBs) and NHS providers to leverage NHS buying power.

A large proportion of NHS procurement is managed through frameworks with NHS Supply Chain (NHSSC). Owned by NHS England, its principal activity is to source, deliver and supply healthcare products, services and food for NHS trusts and healthcare organisations across England. It manages more than eight million orders per year, resulting in over twenty-eight million lines of picked goods distributed to the NHS annually, across a catalogue of up to 600,000 products. Other NHS England procurement functions also apply modern slavery due diligence in accordance with this statement.

Integrated Care Systems (ICSs) were established in July 2022 and provide a legal entity to formalise a partnership-based working approach. They support the creation of NHS policy, strategy, priorities and delivery solutions with national partners and system stakeholders. Integrated Care Boards act as the NHS lead within an ICS, responsible for planning and funding NHS services, fostering collaboration and co-operation across the ICS to deliver on the 4 core purposes of the ICS:

• improve population health and healthcare
• tackle inequalities in outcomes, experience and access
• enhance productivity and value for money
• help the NHS support broader social and economic development

Further details about what we do can be found on our website.

2. Policies in relation to modern slavery and human trafficking

NHS England fully supports the Government’s ambition to eradicate modern slavery and human trafficking and recognises the significant role the NHS must play in both mitigating it and supporting victims. This includes a commitment to work towards supply chains, and business activities, that are free from ethical and labour standards abuses.

There is a clear link between the risk of modern slavery and supply chain resilience and ensuring patients receive consistently safe, high-quality care. The NHS has standardised its approach to identifying modern slavery risk and how it is addressed through procurement to leverage NHS buying power and streamline the approach to eradicating modern slavery for commercial teams and the supply chain. Actions to address risk have been integrated into broader NHS commercial policies and processes wherever possible, including:

• Modern slavery requirements are included in the NHS Terms and Conditions for the procurement of goods and non-clinical services, which govern how we engage with our suppliers and requires compliance with relevant legislation, including the Modern Slavery Act 2015.  
• Modern slavery requirements are built into the 2025/26 NHS Standard Contract for the commissioning of healthcare services to support a consistent approach to risk management through procurement.
• Enabling NHS suppliers to share their progress on modern slavery with all NHS commercial teams through the NHS Evergreen Sustainable Supplier Assessment embedded within Atamis (the NHS-wide e-commerce platform).
• The Strategic Framework for NHS Commercial, published in 2023, seeks to drive collaboration, leverage buying power and provide clear, consistent guidance, including embedding modern slavery into NHS commercial practices.
• The NHS Contract Management Framework requires gold contracts to use the government’s Modern Slavery Assessment Tool to manage contracts.

NHS England supports NHS service providers to align to government policy, and through the delivery of its statutory functions, sets policy to oversee and support providers to eradicate modern slavery. This includes:

• Procurement Policy Note (PPN009) Tackling Modern Slavery in Government Supply Chains, states actions must be taken to ensure modern slavery risks are identified and managed effectively in government supply chains.
• Freedom to Speak Up policy– including ‘freedom to speak up’ Guardians and the Freedom to Speak Up reporting platform, supporting NHS staff to raise issues on anything that is harming the provision of healthcare services.

NHS England specific internal policy further supports our commitment to eradicating modern slavery, including:

• Safeguarding policy (internal document) – defines safeguarding concerns, which relate to forms of abuse including modern slavery and sets out roles, responsibilities, related policy and actions to prevent, or identify and respond to safeguarding concerns.

NHS England is a ‘prescribed person’. That means it can receive protected disclosures and must report annually on the disclosures it receives and the actions it has taken in response. This allows secondary and primary care staff working at NHS trusts, NHS foundation trusts, GP surgeries, opticians, pharmacies and dental practices to raise concerns about inappropriate activity with NHS England directly. The latest NHS England published report is the Annual report on whistleblowing disclosures made to us by workers for 2023/24.

A public consultation was launched in late 2024, seeking views on new regulations (as required by NHS Act (2006) S.12ZC), and supporting NHS guidance as drafted by the Department of Health and Social Care (DHSC) in partnership with NHS England. The consultation was supported by a series of public webinars, providing commercial teams and the supply chain with the opportunity to understand the proposals and encourage feedback through the formal consultation process.

The draft regulations and guidance propose alignment to the requirements set out in PPN 009. The regulations propose placing legal duties on public bodies to manage modern slavery risks when procuring products and services for the health service. NHS guidance aims to support public bodies to consistently comply with the regulations. The findings of the review of the risk of modern slavery and human trafficking in the NHS supply chain (see section 4) were considered in the drafting of both the regulations and guidance.

Future actions:

• Adopt the Cabinet Office Terms and Conditions for procurement covering modern slavery risk management to enhance consistency across government.
• Require NHS organisations to consistently manage modern slavery risk through NHS procurement by publishing related amendments to the NHS Standard Contract for the commissioning of healthcare services.
• Support DHSC in the parliamentary process to lay new regulations following the public consultation.
• Publish NHS guidance on tackling modern slavery in NHS procurement.

3. Due diligence process

We have adopted the Cabinet Office’s Social Value Model (Procurement Policy Note 002), which replaces PPN 06/20, and requires a minimum 10% weighting in all procurements dedicated to delivering social and economic value that supports the government’s missions, including the elimination of modern slavery. Guidance on applying the Social Value Model in healthcare settings has been provided.

Following the launch of the NHS Strategic Commercial Framework, Atamis has been adopted across the NHS as the e-commerce system for the health family to manage the procurement and contracting process. Supporting templates to manage modern slavery risk through the relevant stages of the process have been built into the system. These include the:

• Modern Slavery Risk Assessment Tool (MSRAT) – providing a consistent assessment and rating of risk at pre-procurement stage based on category of spend.
• Government’s standard participation questionnaire – building in mandatory participation questions and exclusionary grounds addressing modern slavery risk.
• Cabinet Office’s Social Value Model (Procurement Policy Note 002), incorporating social value award criteria including outcomes, model questions and sub-criteria
• Contract specific key performance indicator records to support contract management.

The process expected to be followed for managing existing NHS England contracts is defined in the Contract Management Framework (CMF) whereby requirements are aligned to the strategic importance of a contract. It recommends actions to take as part of normal contract delivery and when things go wrong. It specifically sets out the requirement for gold contract suppliers to complete the MSRAT and to incorporate the MSRAT implementation plan into contract management processes.

The NHS Supply Chain Modern Slavery Statement sets out their approach to modern slavery supply chain risk management and adopting related government policy. Due diligence activity incorporates:

• Pre-procurement risk assessment to define the framework risk level.
• Application of support tools (MSAT, social value question, and third-party audits) based on framework risk level to understand the proposed supply chain risk, with defined pass criteria.

Our safeguarding accountability and assurance framework (SAAF) sets out the safeguarding roles and responsibilities of all individuals working in providers of NHS-funded care settings and NHS commissioning organisations. It supports the NHS by providing guidance and minimum standards.

Future actions:

• Publish an update to NHS social value guidance to align to the updated social value model.
• Review and update the CMF to align with the requirements of new NHS guidance.
• Identify opportunities to support a centralised approach to modern slavery risk mitigation.
• Establish a robust and streamlined approach to supply chain mapping to increase transparency and insight including opportunities for auditing aligned with international standards and reporting platforms to mitigate cost and burden for suppliers.

4. Risk assessment and management

The review of the risk undertaken with NHS Supply Chain identified the top 5 products for risk of modern slavery from the NHS England Supply Chain catalogue of 600,000 products as surgical instruments, gloves, gowns, uniforms, and face masks. The review set out a number of actions under 4 areas of recommendation. Complete actions as set out in this statement include the drafting of new regulations and guidance, and the introduction of a risk assessment tool.

In readiness for the introduction of new NHS guidance, a Modern Slavery Risk Assessment tool has been built into Atamis. This enables commercial teams across the health family to adopt a consistent risk identification methodology and standardised approach to product level risk management. This addresses two of the actions set out in the review of risk report. The tool was introduced as a pilot and uses industry data to assign a risk level of high, medium or low in pre-procurement.

Future actions:

• Update risk data built into the Modern Slavery Risk Assessment Tool in Atamis.

5. Key performance indicators to measure effectiveness of steps being taken

The adoption of Atamis as the e-commerce system for the NHS will enable improved monitoring of modern slavery risk management through NHS procurement and inform ongoing enhancement of support tools and processes across the NHS. Reporting of our progress on eradicating modern slavery through the procurement process is undertaken annually through the publication of modern slavery statements.

Future actions:

• Define and build risk assessment and management monitoring reports into Atamis.
• Define governance and reporting structures to monitor performance.

6. Training on modern slavery and human trafficking

The introduction of the modern slavery risk assessment tool into Atamis was supported through engagement activities across the NHS, including:

• In-depth workshops for NHS organisations commercial leads for modern slavery.
• Introductory webinars and on-demand content covering the application of the tool in Atamis.
• Bitesize training videos covering key asks identified through workshops to enhance understanding of the tool and confidence in its application.
• Presentations to the NHS’ internal Sustainable Procurement Forum, which convenes sustainability, clinical and procurement professionals across the NHS.

A training needs analysis is underway to assess the commercial skills and competencies of the workforce including modern slavery will identify where there are skills gaps and where further activity may be undertaken nationally on behalf of stakeholders.

NHS England staff are required to complete compulsory training modules, with awareness of modern slavery addressed through Safeguarding Level 1. Additional safeguarding support tools have been developed for staff groups from safeguarding leads through to the wider healthcare profession.

Evidence has shown that when victims present in healthcare services, healthcare professionals are not always equipped to know how best to support them. To help staff recognise and respond to suspected incidents of modern slavery within the NHS, new e-learning has been created for NHS safeguarding leads. The training supports them to provide clear and strategic leadership for complex cases and enables them to offer the appropriate support to frontline healthcare professionals.

The intercollegiate documents for safeguarding adults, safeguarding children and looked after children, updated in 2024 continues to support healthcare professionals to identify the knowledge and skills needed for safeguarding, including modern slavery. Setting out 5 competency levels for practitioners and Board level, training and support tools developed include:

• Adult Safeguarding: Roles and Competencies for Health Care Staff (RCN 2024)
• Level 1: A free NHS safeguarding agile guide providing an easy-access source of guidance on types of abuse, exploitation and neglect including modern slavery.
• Level 2+: The NHS Learning Platform provides background and updates on safeguarding and trauma-informed practice, signposts clinicians and practitioners to the Modern Slavery Helpline for advice and provides guidance when to contact a first responder.
• Level 3+: Safeguarding webinars and ‘learning together weeks’ hosted on the NHS safeguarding collaborative FutureNHS workspace.

Future actions:

• Develop a plan to upskill NHS staff and the supply chain on modern slavery risk and the new processes informed by the training needs analysis.
• Continue to engage with NHS organisations through NHS England’s regular sustainable procurement forums, workshops, webinars and other events to increase awareness of modern slavery risks and help to upskill our stakeholders.

Summary statement

We continue to work collaboratively across government and take a public health approach to meet the intent to eradicate modern slavery, protect the health and wellbeing of victims and survivors, raise wider awareness and ensure consistency of approach. Further details can be found on our website.

Fiona Bride, Chief Commercial Officer (Interim), NHS England
April 2025