MODERN SLAVERY AND HUMAN TRAFFICKING POLICY AND STATEMENT (Lead Nurse Limited)

Last updated: 24 February 2026

1. Policy statement
   Lead Nurse Limited (“Lead Nurse”, “we”, “us”, “our”) is committed to preventing modern slavery and human trafficking in our business and our supply chains. We have a zero-tolerance approach to modern slavery and will act ethically and with integrity in all our dealings and relationships.

2. Scope
   This policy applies to:

• all employees, directors and officers of Lead Nurse,

• agency workers, contractors and consultants engaged by us, and

• suppliers, partners and service providers we work with.

3. Our business and risk context
   Lead Nurse is a nursing agency that sources and supplies staffing to health and social care organisations. We recognise that labour supply chains can carry heightened risk of exploitation, particularly where individuals may be vulnerable due to immigration status, financial pressure, language barriers, dependency on accommodation, or coercion by third parties.

4. Our commitments and controls
   We take practical steps to reduce the risk of modern slavery and exploitation, including:

a) Ethical recruitment

• We provide clear information about roles, pay, working hours, and assignment conditions before work begins.

• We do not tolerate recruitment practices that involve coercion, deception, intimidation, or withholding of identity documents.

• We do not knowingly work with any party that charges unlawful recruitment fees to workers.

b) Right to work and identity checks

• We verify identity and eligibility to work in the UK before a worker is supplied to a client.

• We check and retain evidence of right to work in a secure manner and in line with data protection obligations.

c) Compliance and suitability checks (role-dependent)

• We verify relevant professional registration (e.g., NMC) where applicable.

• We obtain references and carry out vetting consistent with the role and client requirements.

• Where required, we facilitate DBS checks and handle related information securely and lawfully.

d) Fair pay and transparent terms

• We issue written terms/engagement information and pay people in line with agreed rates and applicable law.

• We do not tolerate unlawful deductions or practices that create debt bondage or dependency.

e) Safeguarding and whistleblowing

• We encourage anyone working with or through us to report concerns without fear of retaliation.

• We investigate concerns promptly and take appropriate action, including referral to appropriate authorities where needed.

f) Supplier and partner expectations

• We expect suppliers and partners to uphold standards consistent with this policy.

• Where appropriate, we may conduct checks or request assurances that suppliers have suitable controls in place.

5. Recognising warning signs
   Indicators may include (non-exhaustive):

• a worker appears fearful, controlled, or unable to speak freely;

• someone else speaks on the worker’s behalf or insists on being present;

• withholding of passports/identity documents;

• threats, intimidation, or unusual restrictions on movement;

• unexplained deductions from pay, or unclear pay arrangements;

• signs of poor living conditions, dependency, or exploitation.

6. Reporting and responding to concerns
   If you suspect modern slavery or human trafficking linked to Lead Nurse’s business, report it immediately:

• Email: info@leadnurse.co.uk

If there is immediate danger, call 999.

We will assess concerns and may:

• suspend placements or supplier relationships pending investigation,

• support the individual to access help,

• report to the police or relevant bodies where appropriate, and

• cooperate with clients and authorities.

You can also contact the UK Modern Slavery & Exploitation Helpline: 08000 121 700.

7. Training and awareness
   We will provide appropriate awareness and guidance to relevant staff involved in recruitment, onboarding, and worker/client management so they can identify and respond to risks.

8. Accountability and review
   Responsibility for this policy sits with Lead Nurse’s senior management. We review this policy periodically and update it as needed.

9. Approval
   Approved by: The Director, Lead Nurse Limited
   Date: 24 February 2026