Modern Slavery and Human Trafficking Policy

APLUS Medical Services & Training Ltd

Version: 1.0
Publication date: 07 January 2026
Review date: January 2027, or earlier if legislation or NHS requirements change
Applies to: All employees, associates, contractors, and suppliers

Purpose and NHS Tender Alignment

This Modern Slavery and Human Trafficking Policy sets out the commitment of APLUS Medical Services & Training Ltd to preventing modern slavery, forced labour, human trafficking, and exploitation within its operations and supply chains.

The policy is designed to meet the requirements of NHS procurement processes and public-sector tendering. It demonstrates appropriate governance, proportionate risk management, and effective control measures in line with NHS supplier assurance standards and the UK Social Value Model.

Legal and Regulatory Framework

This policy is aligned with the Modern Slavery Act 2015 and relevant UK employment, safeguarding, and labour legislation.

APLUS Medical Services & Training Ltd recognises its responsibility to identify, prevent, and mitigate the risk of modern slavery, and to implement appropriate policies, procedures, and controls across its business activities.

Organisational Overview and Risk Context

APLUS Medical Services & Training Ltd is a UK-based provider of medical, first aid, and clinical training services. Training is delivered across healthcare, workplace, and community settings using employed staff and contracted associates.

The risk of modern slavery within APLUS’s direct workforce is assessed as low due to UK-based recruitment practices and regulatory oversight. However, potential indirect risks may exist within extended supply chains, including the procurement of training equipment, printed materials, venues, and outsourced services.

Policy Statement and Commitment

APLUS Medical Services & Training Ltd operates a zero-tolerance approach to modern slavery and human trafficking.

We are committed to acting ethically and with integrity in all business relationships and to implementing effective systems and controls to prevent modern slavery within our organisation or supply chains.

Governance and Accountability

Overall accountability for this policy rests with Senior Management.

Operational responsibility is shared among management, procurement, and training leads, who implement this policy, manage risks, and ensure compliance within their respective areas.

Risk Assessment and Due Diligence

APLUS undertakes proportionate risk assessments to identify areas where there may be a potential risk of modern slavery.

Risk factors considered include geographic location, sector risk, labour intensity, and the use of third-party suppliers or contractors.

Due diligence measures include, where appropriate:
Right-to-work checks and identity verification
Fair pay and lawful employment practices
Clear contractual terms with associates and suppliers
Supplier confirmation of compliance with relevant legislation

Supply Chain Management and Controls

APLUS expects all suppliers, contractors, and partners to uphold equivalent standards relating to human rights, ethical conduct, and employment practices.

Where proportionate, supplier selection and review include consideration of labour practices, transparency, and willingness to cooperate with audits or information requests.

Training Delivery Specific Risks and Controls

Controls relevant to training delivery include:
Use of UK-based, vetted trainers and associates
Written contracts with clear terms and fair remuneration
Prohibition of recruitment fees or exploitative practices
Oversight of venue and equipment suppliers was selected by APLUS

Reporting Concerns and Whistleblowing

APLUS encourages all staff, associates, and contractors to report concerns relating to potential modern slavery, forced labour, or exploitation.

Concerns can be raised confidentially with management and will be taken seriously. Reports can be made without fear of retaliation, victimisation, or adverse treatment.

Monitoring, KPIs and Continuous Improvement

Compliance with this policy is monitored through periodic reviews, supplier checks, and staff feedback.

Key indicators may include:
Completion of right-to-work checks
Supplier compliance confirmations
Completion of staff training and awareness activities

APLUS is committed to continuous improvement and will update controls and processes where necessary.

Breach Management and Corrective Action

Any breach of this policy will be treated seriously.

Confirmed breaches may result in corrective action plans, contract termination, and referral to relevant authorities where required.

Training, Awareness and Competence

Relevant staff receive guidance and training on recognising and preventing modern slavery and human trafficking.

Awareness is reinforced through onboarding and periodic updates to ensure sustained understanding and compliance.

Declaration and Approval

This Modern Slavery and Human Trafficking Policy is approved by Senior Management and reflects APLUS Medical Services & Training Ltd’s commitment to ethical, responsible, and transparent business practices.

Signed: A Fuller
Role: Director

Date: 07 January 2026