Modern Slavery Policy


Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

At Next Step Nursing Ltd, it is our belief that modern slavery and human trafficking are abhorrent practices that will not be tolerated in our own operations or in our recruitment process, and we will take such steps that are reasonable to ensure that none is present. We are committed to working ethically and with integrity and we require our business partners and clients to do the same.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

The policy applies to all persons working for or on behalf of the Next Step Nursing Ltd, in any capacity, including, directors, office staff, agency workers, contractors, recruitment consultants and any other third-party representative.

Next Step Nursing Ltd expects all who have, or seek to have, a business relationship with the Company to familiarise themselves with this policy and to act in a way that is consistent with its values. The Company will only do business with organisations who fully comply with this policy, or those who are taking verifiable steps towards compliance.

This policy will be used to underpin and inform any statement on slavery and human trafficking that the Company is required to produce further to the transparency in recruitment /supply requirements of Section 54 of the Modern Slavery Act 2015 (MSA).

What Do We Mean by Modern Slavery?

Modern slavery can take many forms; it is a complex and multi-faceted problem.

The Modern Slavery Act (MSA) 2015 covers four key criminal activities:

1) Slavery: where ownership is exercised over an individual

2) Servitude: involves the obligation to provide service imposed by coercion

3) Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty

4) Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them

Other forms of modern slavery, which will not be tolerated but are not specifically referenced in the MSA, include, but are not limited to:

  • Child labour: whilst not always illegal in the jurisdiction in which it takes places, child labour involves the employment of children that is exploitative or is likely to be hazardous to or interfere with a child’s education, health (including mental health), physical wellbeing or social development.

All forms of modern slavery have in common is the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.

Tackling modern slavery requires our clients to play a part and remain vigilant to the risk in all aspect of our business and business relationships.

How the company seeks to Embed the Anti-Slavery Policy in Practice To underpin the commitments laid out in this policy,

Next Step Nursing aims to implement the following measures over the course of the financial year 2019/20:

  • The Company will conduct risk assessments to determine which parts of the business and which supply chains are most at risk from modern slavery so efforts can be focused on the areas that are most ‘at risk’
  • Where appropriate, as informed by the risk assessment, the Company will engage directly with new clients in respect of the Anti-Slavery Policy to assure them of the measures we have in place to ensure that modern slavery is not occurring within our businesses.
  • Our contractual documentation will incorporate specific prohibition against slavery or servitude, the use of forced, compulsory or trafficked labour, and the use of child labour in line with this policy.

Responsibility for This Policy

The Directors of Next Step Nursing Ltd has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.

The Compliance Team will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.

The Compliance Team will also ensure all agency workers recruited receive adequate training on this policy and any supporting processes applicable to their role.

The Recruitment Consultants are responsible for ensuring that they comply with the provisions of this policy in the day-to-day performance of their recruitment and supply roles.

Breaches of This Policy

The breach of this policy by an employee, director or recruitment consultants of the Company may lead to disciplinary action being taken in accordance with the Company’s Disciplinary Procedure.

Serious breaches may be regarded as gross misconduct and can lead to immediate dismissal. All employees of the company will be expected to co-operate to the fullest extent possible in any investigation into suspected breaches of this policy or any related processes or procedures.

If any part of this policy is unclear, clarification should be sought from the Clinical Nurse Manager or the Compliance Team.

Recruitment and Selection

Next Step Nursing has appropriate measures and controls are in place to ensure employees including agency staff have the right to work and are therefore protected by employment legislation. This includes checking right-to-work documents, visas and passports

The Company do not employ individuals that would be considered to be ‘child workers’. Young and inexperienced workers may be employed or given work experience, but they are subject to the rights and protections that we afford all workers.

Basic rights which we expect all workers to enjoy, include:

  • The right to a reasonable wage
  • The right to a safe working environment
  • The right to an appropriate level of holiday and cover for period of sickness
  • The freedom to complain directly via our whistleblowing policy free of charge, if they believe that they are not being fairly treated or have any other concerns.

Status of This Policy

This Modern Slavery Policy will be reviewed on a regular basis in response to any regulatory changes. This notice reflects the Company’s current practice.

Next Step Nursing Ltd will update the notice from time to time to reflect legal and operational requirements