Modern Slavery
Policy Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the intentions and actions of MedTop Healthcare Limited and its subsidiaries (here within referred to as the ‘HealthHero Group’ or ‘HealthHero’), to minimise the risk of modern slavery within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The HealthHero Group has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

About the organisation

The HealthHero Group improve lives by using the latest on-demand digital access to bring medical advice from clinical experts to the hands of millions of people, no matter where or when they need it, across the United Kingdom and Europe.

We work closely with regulators, stakeholders, customers, and patients to design and deliver safe, innovative healthcare products and services, remotely and face to face.

Recently formed as a combination of well established, leading clinical businesses, the HealthHero Group continues to grow and evolve. The Group is committed to its responsibilities under the Modern Slavery Act 2015 and to exploring how it can develop its capabilities and culture to do more.

Our policies on slavery and human trafficking

Our internal policies show our commitment to acting ethically and with integrity in all our business relationships.

Currently, new suppliers sign up to our terms and conditions of contract which contain a provision around Good Industry Practice to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains; and that they conduct their businesses in a manner that is consistent with HealthHero policies and procedures.

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

  1. Safe Recruitment. We operate a robust recruitment framework, including conducting eligibility to work in the UK checks for all directly employed staff, and agencies on approved frameworks are audited to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will.
  2. Equal Opportunities. We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities.
  3. Safeguarding Policy. We adhere to the principles inherent within our safeguarding children and adults’ policies. These provide clear guidance so that our employees understand their responsibilities and know how to raise safeguarding concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain.
  4. Whistleblowing Policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals.
  5. Anti-Bribery and Corruption. This code explains the way we behave as an organisation and how we expect our employees and suppliers to act.

Our approach to procurement and our supply chain includes:

  • Ensuring that our suppliers are carefully selected through our robust supplier selection criteria/processes
  • Requiring that the main contractor provides details of its sub-contractor(s) to enable us to check their credentials
  • Where appropriate, requesting that the main contractor provide details of its supply chain
  • Ensuring service agreements contain clauses giving us the right to terminate a contract for failure to comply with labour laws
  • Requiring supplier adherence to our values. We are zero tolerant to slavery and human trafficking and therefore expect all our direct and indirect suppliers/contractors to act in accordance with this.


Advice and training about modern slavery and human trafficking is provided to our staff through safeguarding training programmes, guidance, policies, and procedures. Staff, customers, and patients/clients are supported by our specialist safeguarding leads in the implementation of these principles and policies.

We are continuously looking at ways to increase awareness of modern slavery within our organisation, and to ensure a high level of understanding of the risks related to it in our supply chains and in our business.

Our Approach in 2021

HealthHero is aware of its responsibilities towards patients, clients, employees and contractors and expect all our suppliers to adhere to the same ethical principles. We are committed to modern slavery and human trafficking prevention, throughout our supply chains and in any part of our business.

Forming a new group, we are taking the opportunity to identify and share best practice across our high performing subsidiaries. We will continue to draw on the expertise of our specialist, qualified and compassionate staff to embed respect for human rights and zero tolerance of modern slavery across the business, supply chain and the sector within which we operate.

We understand modern slavery prevention is part of a broader human rights agenda within the business, including corporate action to promote worker protections, civil rights, and community development.

During 2021 we will determine how the development and harmonisation of our policies, mapping and evolution of our ethical supply chain, and maturing of our training programme and grievance mechanisms will contribute towards the prevention of modern slavery.

Performance Indicators 2021

The effectiveness of our commitment and actions to prevent modern slavery and/or human trafficking in our business or supply chain will be indicated by:

  • The embeddedness of escalation and reporting procedures which enable concerns to be raised relating to modern slavery, with all instances managed in accordance with agreed policies and procedures.
  • The maintenance of training compliance throughout the period of 2021 and that any opportunities to enhance content and understanding will be implemented.
  • The information we include in our successive statements continuing to follow best practice, to show we are:
  • acting transparently and disclosing information about any modern slavery risks we have identified and what actions we have taken in response to these;
  • targeting our actions where they can have the most impact by prioritizing according to risks; and
  • making year-on-year progress to address those risks and improve outcomes, where needed, for workers in our business and supply chains.

This policy Statement will be reviewed annually, on or before the 31st January and reissued within 6 months of our financial year end of December 31st.