Action Potential Performance Group Limited

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps taken by Action Potential Performance Group Limited (“the Company”) to prevent modern slavery and human trafficking in its business operations and supply chains.

Modern slavery is a crime and a violation of fundamental human rights. It includes slavery, servitude, forced and compulsory labour, and human trafficking. The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships, as well as implementing and enforcing effective systems and controls to ensure it is not taking place anywhere in our own business or in any of our supply chains.

This policy applies to all individuals working for or on behalf of the Company, in any capacity, including employees at all levels, directors, recruitment consultants, third-party representatives, business partners, and contractors.

The Company operates within the healthcare and life sciences sector and is people-driven and tech-enabled. The majority of Company expenditure is directed toward maintaining and building our workforce, as well as technology systems that support service delivery. Our supply chain includes talent acquisition partners and providers of operational goods and services such as IT and office supplies.

We recognise that modern slavery can occur in any country and sector, and as such we regularly assess our operations and supply chain for risk. In 2023, a cross-functional working group including representatives from Finance, Legal, Operations, and People functions conducted a comprehensive review of risk, identifying suppliers and categories that may warrant additional scrutiny.

Due diligence processes include:

• Risk assessments based on sector, geography, and spending levels.
   
• Review of contract terms with suppliers.
   
• Direct engagement with selected suppliers to assess risk mitigation.
   
• Ensuring modern slavery compliance clauses are embedded in supplier contracts.
   

The Company maintains a suite of policies which contribute to preventing modern slavery, including:

• Recruitment and Selection Policy – ensures fair and legal recruitment practices.
   
• Safeguarding Policies – detail procedures for identifying and escalating risks to vulnerable adults and children.
   
• Whistleblowing Policy – encourages employees and partners to raise concerns confidentially and without fear of retaliation.
   
• Equality, Diversity, and Inclusion Policy – promotes respect, fairness, and non-discrimination in the workplace.
   
• Clinical Governance Policy – outlines responsibilities for ensuring safe, effective, and ethical clinical operations.
   

All Company employees complete annual training on modern slavery, including how to identify the signs of exploitation and how to escalate concerns. Healthcare professionals deployed by the Company are required to complete safeguarding training (Level 2 or Level 3) in line with the Royal College of Nursing’s Intercollegiate Document on Safeguarding.

Every individual working for the Company must ensure they have read, understood, and comply with this policy. The prevention, detection, and reporting of modern slavery is a shared responsibility. Any concerns must be reported to a line manager or Director. Alternatively, concerns may be raised anonymously via the Company’s confidential whistleblowing service.

We support all employees and contractors who report genuine concerns in good faith and will ensure they do not suffer any form of detrimental treatment as a result.

The Company currently adopts a qualitative approach to measuring its effectiveness in combating modern slavery. We continue to monitor and evaluate our processes and will adapt as necessary to ensure ongoing risk mitigation.

Any employee found to be in breach of this policy will be subject to disciplinary procedures, up to and including dismissal for gross misconduct. The Company also reserves the right to terminate relationships with third parties who violate this policy.

Approved by:
Action Potential Performance Group Limited
Date: 23 May 2025