Modern Slavery Policy

Introduction

The Occupational Therapy Service is committed to the highest standards of ethical conduct and integrity in our business activities. We recognize that modern slavery, including human trafficking, forced labour, and child labour, is a global issue that requires vigilance and concerted efforts to eradicate. This policy outlines our commitment to prevent and combat modern slavery within our operations and supply chain.

Scope

This policy applies to all employees, contractors, suppliers, and business partners of The Occupational Therapy Service. It covers all activities and operations of The Occupational Therapy Service, including those of its subsidiaries and affiliates.

Definitions

• Modern Slavery: Encompasses slavery, servitude, human trafficking, forced labour, and child labour as defined by international standards and local laws.
• Forced Labour: Work or service extracted from any person under the threat of a penalty and for which the person has not offered themselves voluntarily.
• Human Trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons by means of threat, force, coercion, abduction, fraud, or deception for the purpose of exploitation.

Commitment

The Occupational Therapy Service is committed to:

• Ensuring that modern slavery is not taking place within our operations or supply chains.
• Conducting risk assessments to identify and mitigate modern slavery risks.
• Implementing and enforcing effective systems and controls to address modern slavery.
• Providing training and resources to employees and suppliers to raise awareness and support the implementation of this policy.
• Regularly reviewing and updating our policies and practices to ensure their effectiveness in combating modern slavery.

Risk assessment and due diligence

The Occupational Therapy Service will:

• Conduct regular risk assessments of our operations and supply chains to identify areas where there is a risk of modern slavery.
• Carry out due diligence on suppliers and contractors, including assessments of their labour practices and compliance with modern slavery laws.
• Require suppliers and contractors to demonstrate their commitment to combating modern slavery through adherence to this policy and related standards.

Reporting and compliance

• Employees, suppliers, and contractors are encouraged to report any concerns or suspicions regarding modern slavery to the designated compliance officer. 
• The Occupational Therapy Service will investigate all reports of modern slavery and take appropriate action, including working with law enforcement and other relevant authorities as necessary. 
• We will not tolerate retaliation against individuals who report concerns in good faith.

Training and awareness

The Occupational Therapy Service will provide regular training to employees, particularly those in roles with a higher risk of encountering modern slavery, to ensure they understand and can identify signs of modern slavery and know how to report concerns.

• We expect our suppliers and contractors to adhere to our standards on modern slavery and to take steps to ensure that no modern slavery occurs in their operations.
• Suppliers must agree to our Supplier Code of Conduct, which includes commitments to ethical labour practices.
• We reserve the right to terminate our relationship with suppliers who fail to comply with this policy or who are found to be involved in modern slavery.

Supplier engagement

• We expect our suppliers and contractors to adhere to our standards on modern slavery and to take steps to ensure that no modern slavery occurs in their operations.
• Suppliers must agree to our Supplier Code of Conduct, which includes commitments to ethical labour practices.
• We reserve the right to terminate our relationship with suppliers who fail to comply with this policy or who are found to be involved in modern slavery.

Monitoring and review

• This policy will be reviewed annually and updated as necessary to reflect any changes in legislation or our operations.
• We will monitor the effectiveness of our actions to combat modern slavery and report on our progress in our annual sustainability report.

Accountability and governance

• The Board of Directors of The Occupational Therapy Service has overall responsibility for ensuring this policy complies with our legal and ethical obligations.
• The compliance officer is responsible for the day-to-day implementation of this policy and for reporting to the Board on its effectiveness.

Communications

• This policy will be communicated to all employees, suppliers, and contractors, and will be made available on our company website

Conclusion

The Occupational Therapy Service is dedicated to maintaining a business free from modern slavery and expects the same commitment from all who work with or on behalf of the company. Through vigilance, education, and collaboration, we strive to play our part in eradicating modern slavery.

For questions or further information about this policy, please contact Lucy Leonard lucyleonard@theotservice.co.ukBy adhering to this policy, The Occupational Therapy Service demonstrates its commitment to ethical practices and the protection of human rights.

Last updated 25 February 2026