It looks like you are in the United States
We have a different site (www.q-bital.com) which better suits your location
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such
as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in
common the deprivation of a person’s liberty by another in order to exploit them for personal or
commercial gain. The Group has a zero-tolerance approach to modern slavery. We will act ethically
and with integrity in all our business dealings and relationships, implementing and enforcing
effective systems and controls to ensure modern slavery is not taking place anywhere in our Group
or our supply chains. We understand slavery and human trafficking are often used collectively.
We are committed to ensuring there is transparency in our Group, business operations and in our
approach to tackling modern slavery throughout our supply chains. This is consistent with our
disclosure obligations under the Modern Slavery Act 2015.
We expect the same high ethical standards from all our contractors, suppliers and other business
partners. As part of our contracting process these standards and requirements form part of our
agreement with our subcontractors.
This statement applies to all persons working for us in our supply chain, on our behalf in any
capacity. This includes employees at all levels, directors, officers, agency workers, seconded workers,
volunteers, agents, contractors, external consultants, third-party representatives and business
partners.
We operate a structured supplier onboarding and approval process which includes assessment of
legal compliance, ethical conduct and modern slavery risks through supplier pre-qualification and
governance controls.
We have developed governance and internal controls to identify concerns or risks about the use of
forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or
children. We have established controls to hold the supply chain to the same high standards. We are
aware of the risks and have controls to manage them and assurance is provided through our
governance structure.
2. The Business
This statement covers the activities of the following UK entities in the Vanguard Group (“Group”):
The Group has been providing flexible clinical infrastructure for over 25 years, including equipment,
staff and ancillary services to both the public and private healthcare sectors in the UK and overseas.
The Group has locations in the UK and Australia. During 2025 we had an average of 110 employees
but, as an organisation we are reliant on agency workers and contractors.
3. The Supply Chain and our People
The supply chain involved in the running of and the design, manufacture and installation of our
flexible clinical structure, and the subsequent provision of staffing and equipment is complex. It
involves multiple levels and different sized organisations. The majority of our suppliers are based in
the UK, Europe or Australia. We use our direct suppliers to help manage the risks of modern slavery
and human trafficking throughout the supply chain. We communicate our expectations and
requirements regarding ethical conduct and compliance standards to suppliers through our
onboarding and procurement processes.
We operate employment policies and procedures that are designed to treat all individuals who work
within our business with dignity and respect. We reward them fairly for their work and do not
exploit them. This applies to engagements with agency workers and contractors. Annual reviews are
undertaken to assess that pay levels remain sufficiently in excess of the National Living Wage. We
undertake appropriate pre-employment checks on all our employees. We require all employment
agencies to do the same. Our People team seek assurances that these checks have been undertaken.
We uphold professional codes of conduct for all our qualified employees and workers.
We work hard to maintain the right culture across the Group. Employees and workers are
encouraged to report any concerns in line with our Freedom to Speak Up: Raising Concerns
(Whistleblowing) Policy. Employees, workers, contractors and suppliers are encouraged to raise
concerns without fear of retaliation and concerns are investigated through the Group governance
framework. We continue to build a culture where individuals trust they can and should, report
concerns without blame. We have a Health, Safety and Environment Manager for the Group, who,
alongside the People team and management structure, are responsible for ensuring the right work
culture is maintained. Our governance structure means lessons learned or errors are reported
organisationally and followed up, informing our continuous improvement processes and ISO9001
accreditation.
We have a pre-qualification process for our supply chain which assesses potential risks relating to
slavery, child labour and human trafficking. As most of our suppliers are based in the UK and
Australia, and many operate in specialised rather than low skilled industries, our supply chains have
been assessed overall as posing a relatively low risk in terms of non-compliance with the Act.
However, supply chain risks are monitored and our pre-qualification processes are updated as
necessary.
We will only work with organisations in our supply chain that have commitments in line with the
Group’s standards and can provide assurance they are not involved in modern slavery, or human
trafficking. While it is the responsibility of those organisations to operate their own policies and
procedures, we monitor compliance through supplier onboarding, pre-qualification processes,
contract management and governance controls.
4. Risk Assessment and Due Diligence
Vanguard recognises that modern slavery risks can arise in different forms across sectors, labour
models and supply chains. Based on our business activities and supply chain profile, we consider the
following areas to present elevated risk:
To mitigate these risks, we operate supplier onboarding and due diligence controls which include:
The Group continues to review and strengthen its supply chain governance arrangements and
supplier engagement processes where appropriate.
Where concerns relating to modern slavery, labour standards or ethical conduct are identified,
Vanguard will assess the issue through its governance and procurement processes and determine
appropriate remedial actions, which may include enhanced supplier engagement, corrective action
plans or termination of supplier relationships where necessary.
5. Actions taken in the last 12 months
During 2025 we:
This statement has been approved by the Board of Directors on 6 June 2025, who will review and update it on an annual basis.
6. Measuring Effectiveness
During 2025 the Group continued to strengthen governance arrangements relating to ethical
procurement and supply chain oversight. Key activities included:
The Group continues to review the effectiveness of these controls through its governance and management structures.
7. Improvement plans
We aim to:
Oversight of modern slavery and ethical supply chain risk is supported through the Group’s governance framework and Board oversight processes.
This statement has been approved by the Board of Directors on 29 May 2026, who will review and update it on an annual basis.
Dr Graham Rich
CEO
8 June 2026
Vanguard Healthcare Solutions
Unit 1144 Regent Court, The Square, Gloucester Business Park, Gloucester, GL3 4AD
We have a different site (www.q-bital.com) which better suits your location