Modern Slavery and Human Trafficking Statement - Apollo Home Healthcare

Modern Slavery and Human Trafficking Statement

Reporting period: Financial Year – 1 April 2025 – 31 March 2026

Apollo Home Healthcare is committed to operating with integrity, safeguarding individuals from harm, and preventing modern slavery and human trafficking in all aspects of its operations and supply chains. This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 and outlines Apollo Home Healthcare’s approach to identifying, preventing and addressing the risks of modern slavery and human trafficking within our organisation and supply chains.

It reflects our ongoing commitment to ethical practice, safeguarding, patient safety and responsible healthcare delivery.

Apollo Home Healthcare recognises that modern slavery risk cannot be fully eliminated. However, we are committed to continuously strengthening our controls, awareness and oversight to reduce the likelihood of exploitation occurring within our operations or supply networks.

Governance and accountability

This statement has been reviewed and approved by the Apollo Home Healthcare Board.

Responsibility for managing modern slavery risk sits across multiple functions including Leadership, Clinical Governance, Quality, Commercial, HR, Operations and Compliance teams. These teams work collaboratively to ensure safeguarding practices, recruitment standards and supplier controls are robust and proportionate.

The Board maintains overall accountability for ensuring that Apollo’s approach to modern slavery prevention remains effective and aligned with legal and sector expectations.

Organisational structure and operations

Apollo Home Healthcare is a private healthcare provider delivering complex care services within community settings across the United Kingdom.

As of 31 March 2026, Apollo employed approximately 1300 colleagues across clinical and operational roles.

We work with a range of clinical and non-clinical suppliers including:

  • Healthcare staffing agencies
  • Clinical equipment and consumables providers
  • PPE, uniform and stationery suppliers
  • IT and digital healthcare partners
  • Professional and advisory service providers

The majority of Apollo’s suppliers are UK-based, although we recognise that supply chains for certain medical consumables and equipment may extend internationally and therefore require additional awareness of modern slavery risk.

Sector risk awareness

Apollo recognises that the healthcare sector can face heightened risks of labour exploitation, particularly in relation to:

  • Agency and temporary staffing arrangements
  • Overseas recruitment of healthcare workers
  • Live-in or community-based care environments
  • Supply chains associated with medical consumables and PPE

We consider these risks when designing safeguarding procedures and supplier due diligence processes. To manage these risks, Apollo undertakes proportionate due diligence activities including supplier screening, right-to-work and identity verification checks, contractual compliance requirements and monitoring of higher-risk supply categories and geographic exposure.

Policies and internal controls

Apollo maintains a range of policies and procedures which support the prevention, identification and escalation of modern slavery concerns. These include:

  • Anti-Slavery and Human Trafficking Policy
  • Safeguarding Adults and Children Policies
  • Recruitment and Right-to-Work Procedures
  • Agency Worker and Contractor Compliance Standards
  • Whistleblowing Policy
  • Anti-Fraud, Bribery and Corruption Policy
  • Health and Safety Policies

These policies are reviewed periodically to ensure alignment with evolving legislation, sector risk and organisational growth.

Risk assessment methodology

Apollo applies a proportionate, healthcare-specific methodology to assess modern slavery risk:

  1. Risk identification – Mapping roles, supplier categories and geographic exposure to identify higher-risk areas.
  2. Due diligence Screening – Requiring relevant suppliers to complete onboarding questionnaires and confirm compliance with anti-slavery legislation.
  3. Control evaluation – Verifying right-to-work checks, recruitment safeguards and employment practices across Apollo and agency partners.
  4. Risk scoring – Assessing inherent and residual risk using likelihood and impact criteria.
  5. Action and monitoring – Implementing corrective actions, conducting targeted reviews and escalating concerns through safeguarding and governance routes.

Actions taken during the reporting period

During the financial year 2025/26 Apollo:

  • Reviewed supplier onboarding processes to strengthen modern slavery due diligence controls
  • Refreshed safeguarding training content to reinforce awareness of exploitation indicators
  • Conducted internal mapping of higher-risk supplier categories including staffing agencies and PPE suppliers
  • Maintained contractual expectations requiring suppliers to uphold ethical labour standards

No substantiated cases of modern slavery were identified within Apollo Home Healthcare’s operations or supply chains during the reporting period.

Reported concerns

During the reporting period Apollo did not identify any substantiated concerns relating to modern slavery within our operations or third-party relationships.

We recognise that absence of reported concerns does not eliminate risk. We therefore continue to prioritise awareness-raising, safe reporting channels and proactive monitoring.

Training and awareness

Apollo provides safeguarding training to all colleagues, which includes awareness of modern slavery indicators and reporting responsibilities.

Targeted training is also delivered to recruitment, procurement and clinical governance teams to strengthen risk identification within workforce and supply chain activities.

Apollo monitors completion rates for mandatory safeguarding and modern slavery awareness training and takes action where uptake falls below expected levels.

Measuring effectiveness and Key Performance Indicators

Apollo monitors the effectiveness of its modern slavery prevention approach through the following indicators:

  • 100% of new suppliers in higher-risk categories to complete modern slavery due diligence prior to onboarding
  • Apollo includes contractual provisions requiring suppliers to comply with the Modern Slavery Act 2015 and reserves the right to terminate relationships where non-compliance is identified.
  • Annual compliance review of the top 20 highest-spend suppliers
  • 100% completion of right-to-work and identity verification checks prior to engagement
  • ≥95% completion rate for safeguarding and modern slavery awareness training
  • 100% of safeguarding or whistleblowing concerns relating to potential exploitation reviewed within 48 hours and escalated in line with governance procedures.
  • Quarterly monitoring of identified higher-risk supply chains
  • Annual review of the Anti-Slavery and Human Trafficking Policy

Continuous Improvement priorities

Apollo will continue to strengthen its approach to modern slavery prevention through ongoing enhancement of supplier controls, increased training uptake, regular review of sector-specific risks, and active engagement with industry best practice.

Approval

This statement has been approved by the Board of Apollo Home Healthcare and signed on its behalf by a director

Signed:

Laura Walker
Managing Director
For and on behalf of Apollo Home Healthcare
31st March 2026

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