NHS England modern slavery and human trafficking statement for 2025/26

An estimated 50 million people live in modern slavery across the world. Modern slavery exists in every country, including the UK, across multiple industries. Its risk is present in healthcare supply chains, our workforce and our patients. Instances of forced and child labour have been documented within the supply chain of the health and social care sector. Healthcare workers are one of the most likely professions to encounter victims of modern slavery presenting as vulnerable patients, and the healthcare workforce is also a sector that may include individuals that are victims of modern slavery.

The National Health Service (NHS) in England is committed to working towards supply chains and business activities including recruitment that are free from ethical and labour standards abuses and supporting vulnerable patients. We recognise the risk of modern slavery in the NHS is wider than supply chain and links into our recruitment and Safeguarding responsibilities. Our approach to mitigation through the supply chain, and relevant recruitment and safeguarding activities is set out in this second group statement for the NHS in England.

The government announced on 13 March 2025 the merger of NHS England with the Department for Health and Social Care (DHSC). This statement covers the steps taken by NHS England to support the wider NHS to address the risk of modern slavery in the health service and the steps the NHS system is expected to take locally. DHSC and NHS England teams continue to work in collaboration to mitigate modern slavery and the approach to future NHS statements will be considered as the organisations integrate. NHS organisations are encouraged to defer to this group statement and link to it directly from their websites rather than produce individual statements.

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 resources, 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 £30 billion across approximately 80,000 suppliers, including medical goods and services, office supplies, cleaning, catering and transport services. NHS England’s Central Commercial Function helps coordinate closer alignment of trusts and Integrated Care Boards (ICBs) 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 8 million orders per year, resulting in over 35 million lines of picked goods distributed to the NHS annually, consolidating orders from over 1100 suppliers, 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 to legally formalise a partnership-based working approach between local partners to create better services based on local need. 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 aims to:

improve outcomes in 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.

Policies in relation to modern slavery and human trafficking

NHS England fully supports the government’s ambition to eradicate modern slavery and human trafficking in healthcare supply chains and recognises the significant role the NHS must play in both mitigating it and supporting victims. This ambition is now backed up by:

The regulations were laid before and approved by Parliament in November 2025 and come into force on 17 May 2026. The regulations and guidance were developed in partnership by NHS England and DHSC and will be supported by delivery of a collective implementation plan to support commercial teams of in-scope organisations prepare for their introduction.

The findings of the review of the risk of modern slavery and human trafficking in the NHS supply chain were considered in the drafting of both the regulations and guidance. The new regulations place legal duties on public bodies to manage modern slavery risks when procuring products and services for the health service and take reasonable steps in proportion to the level of risk. The NHS guidance identifies reasonable steps in alignment to the requirements set out in the existing Procurement Policy Note (PPN 009). The NHS Guidance was updated following the public consultation into the regulations and is now defined by the regulations as statutory guidance: ‘A public body must have regard to any guidance issued by NHS England’ and will support all public bodies in scope to consistently comply.

There is a clear link between the risk of modern slavery and supply chain resilience and ensuring patients receive consistently safe, high-quality care. In alignment with new and existing policy requirements, the NHS has adopted a standardised approach to identifying and rating modern slavery risk to inform how it is addressed through procurement. This will help to leverage NHS buying power for commercial teams and streamline the approach to eradicating modern slavery in the supply chain.

Actions to address risk have been integrated into broader NHS commercial policies and processes wherever possible, including:

the NHS terms and conditions for the procurement of goods and non-clinical services align to the Cabinet Office Standard Contract and include modern slavery requirements, providing a consistent cross-government approach to how we engage with our suppliers and manage modern slavery risk
the NHS Standard Contract (service conditions) include modern slavery requirements for the commissioning of healthcare services, requiring a consistent approach to risk management through procurement
the NHS Evergreen Sustainable Supplier Assessment embedded within Atamis (the NHS-wide e-commerce platform) enables NHS suppliers to benchmark and share their progress to address modern slavery risks with all NHS commercial teams
the Strategic framework for NHS Commercial, published in 2023, supports modern slavery to be embedded into NHS commercial practices by driving collaboration, leveraging buying power and providing clear, consistent guidance
the NHS contract management framework (NHS England specific) requires contract managers to have regard to NHS modern slavery guidance and identify the reasonable steps applied in the procurement that require ongoing contract management, including monitoring of contractual commitments, specification and Key Performance Indicators (KPIs).

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:

PPN 009: Guidance on 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 national 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 (including modern slavery)
The NHS Standard Contract (service conditions) requires service providers to comply with the requirements and principles in relation to safeguarding children, young people and adults with regards to the Modern Slavery Act 2015
Direct NHS recruitment is managed through NHS Business Services Authority on NHS Jobs which manages requirements for pre-employment checks of candidates. Where recruitment agencies are used, they must follow the Code of practice for the international recruitment of health and social care personnel – GOV.UK which promotes high standards of ethical practice in the international recruitment and employment of health and social care personnel
Our Safeguarding accountability and assurance framework defines safeguarding concerns, which relate to forms of abuse including modern slavery. It sets out roles, responsibilities, related policy and actions to prevent, or identify and respond to safeguarding concerns for all individuals working in providers of NHS-funded care settings and NHS commissioning organisations. It supports the NHS by providing guidance and minimum standards.

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 (including modern slavery related activity) with NHS England directly. Further detail can be found at Freedom to Speak Up.

Future actions:

Deliver the joint NHSE/DHSC implementation plan to support the regulations and guidance, including provision of support tools such as an easy read version of guidance and checklist.
Support DHSC with the review of the implementation of the regulations and assess compliance with the requirements as set out in the Government response to the consultation.

Due diligence process

We have adopted the Cabinet Office’s PPN 002: The Social Value Model (replaces PPN 06/20), which 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. NHS Guidance on applying the Social Value Model in healthcare settings has been updated with the publication of the NHS Social Value Playbook.

The Strategic framework for NHS commercial provides a 5 year plan to drive collaboration across NHS commercial teams including embedding consistency in processes. Atamis has been adopted across the NHS as the e-commerce system for the health family to manage the procurement and contracting process. It includes supporting templates and functionality to manage modern slavery risk through the relevant stages of the procurement process including 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 PPN 002: The Social Value Model incorporating social value award criteria, including outcomes, model questions and sub-criteria
Bespoke social value key performance indicator (KPI) templates (under the e-procurement Savings and Benefits in the Contracts module) and monitoring reports to support contract management

The Contract Management Framework (internal document) defines the process for managing existing NHS England contracts where requirements are aligned to the modern slavery risk rating of the contract and the strategic importance of a contract. It recommends actions as part of normal contract delivery and when things go wrong. It specifically sets out the requirement for medium and high-risk contracts and gold contract suppliers to complete the Modern slavery assessment tool [MSAT] and to incorporate the MSAT recommendations into a Performance Improvement Plan.

NHS Supply Chain’s modern slavery statement sets out their approach to modern slavery supply chain risk management and adoption of related government policy. NHS Supply Chain’s due diligence activity incorporates:

pre-procurement risk assessment to define the framework risk level
application of support tools (Modern slavery assessment tool [MSAT], mandatory social value question, and third-party audits) based on framework risk level to understand the proposed supply chain risk with defined pass criteria
supply chain mapping of NHS Supply Chain frameworks (lead by NHS SC) through the cross-government department initiative: Global Supply Chain Intelligence Programme (GSCIP), enabling the review of modern slavery risk in tier one and beyond via supply chain mapping intelligence.

Future actions:

Identify and implement improvements into the health family’s e-procurement infrastructure to support application of the NHS guidance.

Risk assessment and management

The top 5 products for modern slavery risk identified from the NHS Supply Chain catalogue of 600,000 products are surgical instruments, gloves, gowns, uniforms, and face masks.

Atamis has an inbuilt modern slavery risk assessment tool to support the health family to comply with upcoming modern slavery regulations and PPN 009. This enables commercial teams across the health family to adopt a consistent and standardised approach to risk rating procurements by category of spend. The tool uses industry data (updated quarterly) to assign a risk level of high, medium or low in pre-procurement and has enabled activities including:

risk assessment of all workplan, project and contract records submitted in Atamis
Test cases to identify and address risk mapping errors found from the pilot of the risk tool
specific NHS England commercial activities:
creation of a risk report to support monitoring of existing contracts
completed risk assessment of existing NHS England contracts
an MSAT campaign for NHS England high risk contracts, improving monitoring of risk through contract management.

Future actions:

continue to update risk data built into the Modern Slavery Risk Assessment Tool (MSRAT) in Atamis
review the ongoing provision of risk data to support consistent risk assessment of procurements across the NHS.

Key performance indicators to measure effectiveness of steps being taken

The adoption a single e-commerce system for the health family has enabled improved monitoring of modern slavery risk management through NHS procurement and informs ongoing enhancement of support tools and processes across the NHS. Monitoring reports support the ongoing review of risk of existing NHSE contracts.

Reporting of our progress on eradicating modern slavery through the procurement process is undertaken annually through the publication of modern slavery statements and at more regular intervals to the Central Commercial Function Board (internal).

Future actions:

define system governance and reporting structures to monitor performance
define and build suitable management reports into Atamis to monitor system compliance
identify options for a KPI to monitor compliance and effectiveness.

Training on modern slavery and human trafficking

The CCF framework set out to support the development of the commercial workforce by providing a standardised career pathway against a national competency framework, informed by training needs analysis. The NHS Learning and Development Centre of Excellence was established to develop, build and roll out the national training offer addressing skills gaps on behalf of stakeholders, including modern slavery.

Existing modern slavery training available to commercial teams to support the mitigation of modern slavery risk through procurement, includes:

introductory webinars and on-demand content covering the application of the modern slavery risk assessment tool built into Atamis (internal NHS Futures site)
bitesize training videos covering key asks identified through workshops to enhance understanding of the tool and build confidence in its application (internal NHS Futures site)
Government Commercial College: Tackling modern slavery in supply chains: PPE case study
presentations to the NHS Sustainable Procurement Forum (internal), which convenes sustainability, clinical and procurement professionals across the NHS

NHS England staff mandatory training modules address awareness of modern slavery 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, e-learning for NHS safeguarding leads is available. 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 document (2025) Safeguarding children and young people & children and young people in care, continues to support healthcare professionals to identify the knowledge and skills needed for safeguarding, including modern slavery. The training sets 5 competency levels for practitioners and Board members. 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 internal NHS safeguarding FutureNHS collaborative workspace

Future actions:

deliver webinars and training materials to support the roll out of new regulations and NHS guidance
develop and build the modern slavery commercial e-learning module as part of the NHS Learning and Development Centre of Excellence
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 upskill 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, Director General, Commercial and Growth and Chief Commercial Officer (Interim), NHS England
May 2026