Tackling modern slavery together: how NHS Supply Chain provides assurance to the health and care system
Modern slavery is a hidden but significant risk within global supply chains, including those that support the NHS. From May 2026, new NHS procurement regulations relating to modern slavery and human trafficking will come into force, increasing the level of scrutiny placed on how these risks are identified and managed across procurement and contract activity.
These regulations formalise a clear legal duty on the NHS, prompting trusts, Integrated Care Systems (ICSs) and system partners to seek greater assurance that the suppliers and frameworks they rely on meet strengthened national requirements.
Alongside this, we are hearing consistent questions from across the system:
- What does this mean in practice?
- Where does the responsibility lie?
- How can meaningful assurance be demonstrated given the complexity of global healthcare supply chains?
NHS Supply Chain sits at the centre of this challenge, and we recognise the responsibility that comes with our role. By sourcing and managing products and services on behalf of the NHS, we play a critical role in embedding a consistent, proportionate and evidence‑based approach to modern slavery, supporting the system to meet its legal duties while reducing duplication of effort at local level.
Modern slavery is not only a legal and ethical issue; it is a system‑wide challenge that requires collaboration, transparency and continuous improvement. This article sets out our approach and the assurance it provides to the wider NHS.
Why modern slavery matters to the NHS
Modern slavery refers to situations where people are exploited through forced labour, servitude or human trafficking. It is often deeply embedded in complex, multi‑tier global supply chains, particularly where there is reliance on low‑cost manufacturing, temporary and migrant labour or commodity‑based raw materials such as cotton and rubber.
Healthcare supply chains are not immune. Products such as medical gloves, surgical instruments, gowns, uniforms and other textiles are recognised internationally as higher risk due to the conditions in which they are often manufactured. Exploitation tends to sit further upstream, beyond tier‑one suppliers, making visibility and proactive due diligence essential.
For the NHS, this matters because patient care must never be delivered at the expense of human rights elsewhere in the system. It also matters because legislation now places a clear duty on NHS organisations to identify and address these risks.
Our mandate to act: from compliance to system assurance
The NHS approach to modern slavery has strengthened significantly in recent years. This includes:
- The Modern Slavery Act 2015, requiring transparency in supply chains.
- The Health and Care Act 2022, placing a duty on the NHS to assess and address modern slavery risk.
- Procurement Policy Note (PPN) 009, aligning with the Procurement Act 2023.
- The NHS (Procurement, Slavery and Human Trafficking) Regulations 2025, coming into force from May 2026.
Together, this framework moves the NHS beyond statements of intent and towards demonstrable, proportionate action.
As a central procurement organisation, NHS Supply Chain plays a critical role in meeting these duties at scale. Our approach is designed to give trusts and ICSs confidence that modern slavery risks are being assessed and managed consistently across the frameworks they use.
A clear, risk‑based approach built into procurement
Modern slavery risk is not treated as a standalone issue. Instead, it is embedded throughout our procurement and contract management lifecycle.
Before a procurement begins, we assess the inherent risk using the standard NHS England methodology aligned to PPN 009. This considers the following factors:
- Industry type.
- Nature of workforce.
- Business/supply chain model.
- Supplier location.
- Commodity type.
- Context in which the supplier operates.
Each procurement is rated as low, medium or high risk, ensuring that effort is focused where it matters most.
During sourcing and tendering, suppliers are required to meet clear minimum standards:
- Completion and ongoing maintenance of the Modern Slavery Assessment Tool (MSAT).
- Compliance with NHS Terms and Conditions and our Supplier Code of Conduct.
- Alignment with wider social value and sustainability requirements.
Where risks are higher, we apply enhanced due diligence. This can include:
- Detailed evidence reviews.
- Independent third‑party audits.
- Deeper scrutiny of supply chain controls and worker protections.
Importantly, we do not rely on scores alone. MSAT and audit outputs are interrogated to understand the real‑world risks and the effectiveness of supplier actions.
Acting on issues, not just identifying them
Identifying risk is only meaningful if it leads to action.
Where concerns are raised, whether through audits, whistleblowing, media reports or third‑party intelligence, we follow a structured response process. This includes immediate steps to prevent harm, corrective actions to address root causes, and preventative measures to reduce the likelihood of recurrence.
Suppliers are expected to engage openly and transparently. Our focus is on improvement and protection of workers, while being clear that failure to address serious issues can affect ongoing commercial relationships.
Transparency, reporting and continuous improvement
See our Useful Links section for our public Modern Slavery Statement and Social Value Report. These documents set out how we are performing and where we are focusing our efforts. This includes:
- 100% supplier completion of MSAT for in‑scope contracts.
- Use of supply chain mapping and government intelligence to improve upstream visibility.
- Integration of modern slavery into our broader social value and responsible procurement approach.
- Mandatory training for colleagues, recognising that capability across the organisation is essential.
For NHS customers, this transparency supports your own governance, audit and regulatory requirements.
What this means for trusts and ICSs
By using NHS Supply Chain frameworks, trusts and systems can be confident that:
- Modern slavery risk is assessed before contracts are awarded.
- Due diligence is proportionate, evidence‑based and aligned with national policy.
- Issues are actively managed, not just reported.
- A consistent approach is applied across categories and suppliers, reducing duplication and risk.
This supports local decision‑making while reinforcing a collective NHS response to a global challenge.
Working together for responsible supply chains
Modern slavery cannot be eliminated by one organisation alone. It requires collaboration across the NHS, suppliers, government and international partners.
Our commitment is to continue strengthening our approach, learning from emerging risks, and sharing assurance with the systems and organisations we serve. In doing so, we help ensure that the NHS supply chain reflects the values of fairness, dignity and respect that sit at the heart of patient care.
What this means for NHS trusts and ICSs
Modern slavery is a serious human rights issue that can sit deep within global healthcare supply chains. As a central procurement organisation for the NHS, we have both a legal duty and a system responsibility to identify, assess and address these risks on behalf of the trusts and systems we serve.
We embed modern slavery risk assessment and due diligence into the full procurement lifecycle. This means that before contracts are awarded, risks are identified, proportionate checks are carried out, and clear expectations are set with suppliers. This provides confidence that frameworks used by trusts and ICSs meet national policy and regulatory requirements.
Yes. By applying a consistent, nationally aligned approach at scale, NHS Supply Chain helps reduce duplication of effort across the system. Our frameworks provide a strong baseline of assurance, supporting local governance, audit and reporting requirements without trusts having to repeat supplier-level due diligence.
Where a procurement is identified as higher risk, we apply enhanced due diligence. This can include deeper evidence reviews, third‑party audits and greater supply chain visibility. These measures are focused on risk mitigation and improvement, with worker protection at the centre.
We have a clear, structured response process. This includes immediate actions to prevent harm, corrective actions to address root causes, and longer‑term preventative measures. Suppliers are expected to engage transparently, and issues are actively monitored through the life of the contract.
Our approach aligns with the Modern Slavery Act, the Health and Care Act and NHS procurement guidance. It supports trusts and ICSs in meeting their statutory duties while contributing to a coordinated NHS response to modern slavery risks across the system.
Yes. We publish our Modern Slavery Statement and Social Value reporting annually, and we engage with NHS stakeholders where further assurance or clarification is required.
Summary
By using NHS Supply Chain frameworks, trusts and ICSs can be confident that modern slavery risks are being identified, managed and monitored in a consistent, proportionate and transparent way, supporting ethical procurement and the values at the heart of the NHS.