Modern Slavery Act 2026
The Modern Slavery Act 2015 requires those entities carrying on a business or part of a business in the UK, supplying goods or services, and having an annual turnover of £36 million or more to disclose information regarding the steps they have taken to eradicate slavery and human trafficking from their supply chain as well as within their own organisation during the previous financial year.
MODERN SLAVERY ACT STATEMENT
It continues to be a priority for Lloyds Clinical Limited to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and highlights the key activities we have undertaken during the financial year ending 31 March 2026 to combat modern slavery in our organisation and supply chain.
BUSINESS STRUCTURE AND ORGANISATION
Lloyds Clinical Limited is part of the Hallo Healthcare Group and has its head office in the UK.
Lloyds Clinical Limited is one of the most experienced providers of omnichannel clinical homecare in the UK and has been supporting patients in this way since 1975. We provide care to around 100,000 patients in their own home or a community-based setting, with our services including dispensing and delivery of medication direct to patient, specialist nursing (face to face or remotely) and patient support programmes for complex conditions, and compounding of medicines from our dedicated compounding facilities. We work in partnership with the NHS, pharmaceutical manufacturers, private medical insurers, and consultants, supporting a range of simple and complex patient needs.
OUR POLICIES, VALUES AND TRAINING
We have appropriate policies in place that underpin our commitment to combat modern slavery and human trafficking in our supply chains or in any part of our business. During 2025/26, the organisation reviewed its modern slavery and supplier assurance arrangements in light of emerging legislative and regulatory developments. In particular, we considered the implementation of the Procurement Act 2023, the Economic Crime and Corporate Transparency Act 2023 and the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025, which strengthen expectations relating to the identification, assessment and management of modern slavery risks within public sector and NHS supply chains.
As a healthcare provider delivering services to NHS patients, Lloyds Clinical is committed to conducting business ethically and with integrity, maintaining effective systems and controls to prevent modern slavery and human trafficking within our operations and supply chains. Our Modern Slavery and Human Trafficking Policy outlines a risk-based approach to supplier due diligence, contract management, and ethical sourcing. We recognise that indicators of modern slavery may arise within clinical settings and provide colleagues with training to identify concerns and escalate them through established safeguarding processes.
We also have the following policies in place relevant to modern slavery and business relationships, which are reviewed and updated regularly:
- Code of Conduct
- Recruitment Policy
- Procurement Policies
- Whistleblowing Policy
- Anti-Bribery and Corruption Policy
- Grievance Policy
We are committed to sourcing quality products from, and building relationships with, suppliers who share our values and ethical standards. We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
Our Code of Conduct provides important guidelines for interactions with customers, suppliers, and other business partners. At the core of the Code of Conduct and our activities are our values and behaviours which are Delivering Together, Being Accountable, Giving it our all, Continually Improving.
We are an equal-opportunities employer committed to creating and ensuring a non-discriminatory and respectful working environment for our colleagues. Our recruitment and people management processes are designed to ensure that all prospective colleagues are legally entitled to work in the UK and to safeguard colleagues from any abuse or coercion once in our employment.
We want all our colleagues to feel confident that they can expose wrongdoing without fear of retaliation.
Our Whistleblowing Policy encourages all colleagues to raise concerns including potential violations of the Code of Conduct, company policies, and the laws of the countries in which we operate. We have reporting mechanisms in place to collect and relay information regarding potential violations to appropriate company resources for review and follow up action.
These reporting mechanisms include a UK-based confidential helpline which is available 24 hours a day, 7 days a week, and a Statutory Board Escalation Process which ensures that colleagues are aware of those matters requiring immediate escalation to the Statutory Directors of Lloyds Clinical Limited.
We provide online and/or face to face training for colleagues to emphasise the importance of acting with integrity and in line with our values and behaviours, principles, and Code of Conduct.
SUPPLY CHAIN AND DUE DILIGENCE
Our supply chain comprises manufacturers, distributors and service providers supporting the delivery of homecare, pharmacy, nursing, and patient support services. The majority of our key suppliers operate within highly regulated healthcare and pharmaceutical sectors; however, we recognise that modern slavery risks can arise at different tiers of the supply chain and may be more prevalent in certain geographies, industries, and labour-intensive activities.
To address these risks, we operate a risk-based supplier assurance programme designed to identify, assess, and manage potential modern slavery and human trafficking risks throughout our supply chain. This includes due diligence activities undertaken during supplier onboarding, contract award, and ongoing supplier relationship management.
As part of our supplier due diligence process, suppliers may be assessed against a range of criteria including regulatory compliance, ethical business practices, quality standards, labour practices, and supply chain transparency. Where a supplier, product category or geographic region is identified as presenting an elevated risk, enhanced due diligence and additional monitoring may be undertaken.
We communicate our expectations through our policies, supplier engagement activities, and contractual arrangements. Supplier agreements include provisions requiring compliance with applicable laws relating to modern slavery, forced labour and human trafficking, and we reserve the right to seek assurances or take appropriate action where concerns are identified.
In higher-risk areas of the supply chain, we utilise both internal expertise and external assurance mechanisms to evaluate suppliers against recognised industry standards. Any findings arising from audits, assessments or supplier reviews are evaluated using a risk-based approach, with corrective actions agreed, monitored, and reviewed to support continuous improvement.
We seek to work collaboratively with suppliers to strengthen ethical and responsible sourcing practices. Where suppliers are unwilling or unable to address material concerns relating to modern slavery or human rights, we will review the commercial relationship and consider appropriate remedial action, including termination where necessary.
EFFECTIVENESS
We regularly review the effectiveness of our supply chain risk management and supplier assurance processes to ensure our controls remain robust and aligned to evolving risks. Through these activities, we continue to strengthen our approach to preventing, identifying, and addressing modern slavery and human trafficking risks within our operations and supply chain.
Training sessions for existing colleagues on the key compliance risks affecting our business and inductions for new starters include the topics of supplier due diligence and modern slavery and human trafficking as appropriate.
Modern slavery risks are captured in our Corporate Risk Register.
STATEMENT OF APPROVAL
This Statement has been approved by the Board of Directors of Lloyds Clinical Limited, and the Board has authorised Sean Feeney Chief Executive Officer, to sign the Statement on behalf of Lloyds Clinical Limited.
Sean Feeney
Chief Executive Officer
30 September 2026