Modern Slavery Policy and Statement (UK)

Modern Slavery and Human Trafficking Policy & Statement – Thema Ltd
Contact: info@thema-healthcare.co.uk

1. Our commitment

Thema Ltd is committed to preventing modern slavery and human trafficking in our business and supply chains. We have a zero-tolerance approach to forced labour, servitude and human trafficking.

2. Legal context and scope

Section 54 of the Modern Slavery Act 2015 requires certain commercial organisations operating in the UK with a turnover of £36 million or more to publish an annual modern slavery statement, approved by the board and signed by a director, and published with a homepage link. 

If Thema Ltd is not legally required to publish a statement, we adopt this policy and statement voluntarily as good practice and to support transparency in the recruitment sector. UK Government guidance encourages wider adoption of meaningful reporting. 

3. Our business and supply chains

We operate as a Healthcare Recruitment Agency, supplying temporary and/or permanent staff to health and social care providers. Our supply chain may include:

  • Candidate attraction channels and job platforms

  • Payroll

  • Vetting and compliance providers (DBS, referencing, training)

  • IT/CRM/ATS suppliers and professional advisers

4. Risk assessment

We recognise risks may arise in:

  • Labour supply chains, particularly where workers are dependent on a third party for work, transport, accommodation, or documentation

  • Subcontracting arrangements (e.g., umbrella companies)

  • High-pressure financial vulnerability and coercion indicators

We review risks periodically and when entering new supply arrangements.

5. Due diligence and controls

We take steps to prevent and mitigate risks, including:

  • Worker identity verification and right-to-work checks

  • Clear written terms/engagement information and transparent pay arrangements

  • Supplier onboarding checks (including modern slavery controls where relevant)

  • Reporting channels for concerns, including confidential escalation routes

  • Contractual expectations for suppliers to comply with applicable laws and ethical standards

6. Training and awareness

We provide (or plan to provide) training for relevant staff on:

  • Recognising indicators of modern slavery and labour exploitation

  • Safe recruitment practices and ethical supply chain management

  • How to report concerns

7. Reporting and remediation

Any suspicion or evidence of modern slavery will be treated seriously and escalated promptly. Where appropriate, we will:

  • Suspend or terminate relationships with suppliers who do not remediate issues

  • Work with clients and competent authorities to protect affected individuals

  • Record incidents and lessons learned to strengthen controls