Modern Slavery Policy

Draft for client review

Status: Working draft dated 20 July 2026. This policy has been prepared from current official UK guidance for Bruce Penny to review. It is not yet an approved company policy.

Before approval, confirm that the responsibilities and working arrangements below match current practice. Professional legal or safety advice should be obtained where needed.

1. Purpose and scope

This policy applies to Penny Tree Surgery, its owner, workers, trainees, agency workers, subcontractors and any person acting on its behalf. We expect suppliers and business partners to follow equivalent standards where relevant to the work they carry out for us.

2. Status of this document

This is a voluntary operational policy. It is not presented as an annual slavery and human trafficking statement under section 54 of the Modern Slavery Act 2015. The statutory publication duty generally applies to commercial organisations that carry on business in the UK, supply goods or services and have annual turnover of £36 million or more.

Bruce Penny should confirm the business structure and turnover position before approving this document and review that position if the business changes.

3. Our commitment

Penny Tree Surgery will not knowingly use or support slavery, servitude, forced or compulsory labour, human trafficking, debt bondage or the exploitation of vulnerable people. Work must be freely chosen, and workers must be free to leave employment in line with their contract and the law.

• No worker may be charged recruitment fees or required to surrender a passport or identity document.
• Pay, working time, rest and employment arrangements must comply with applicable law.
• Threats, coercion, violence, degrading treatment and restriction of movement are prohibited.
• Workers must be able to raise concerns without retaliation.

4. Suppliers and subcontractors

We use proportionate checks when engaging suppliers and subcontractors, with closer scrutiny where labour is supplied through an intermediary, work is temporary or cash-based, prices appear unrealistically low, or identity and employment arrangements are unclear.

Where a credible concern is identified, we will investigate, protect anyone at immediate risk and seek appropriate advice. We will not take action that knowingly places a potential victim at greater risk. Serious concerns may be reported to the police, the Modern Slavery & Exploitation Helpline or another competent authority.

5. Reporting and response

Workers and business partners should report suspected exploitation promptly to Bruce Penny or use the Whistleblowing Policy. In an emergency call 999. The UK Modern Slavery & Exploitation Helpline can be contacted on 08000 121 700.

Reports will be taken seriously, handled as confidentially as reasonably possible and recorded only where necessary. Retaliation against a person who raises a genuine concern is prohibited.

6. Responsibility and review

Bruce Penny has overall responsibility for this policy, supplier risk decisions and any investigation or escalation. The policy will be reviewed annually and when there is a material change to the workforce, suppliers, services or legal obligations.

7. Official guidance used

Modern slavery statement guidance on GOV.UK

How to identify and support victims of modern slavery on GOV.UK