Introduction
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and outlines the steps taken by Florence to prevent modern slavery and human trafficking in our operations and supply chains during the financial year ending 31 December 2024.
Florence is committed to the highest standards of ethical conduct and continuously improving our practices to safeguard the rights and dignity of all individuals we engage with. We oppose all forms of modern slavery, including forced labour, human trafficking, debt bondage, and child labour.
Our Organisation and Business Model
Florence is a technology-led recruitment company operating in the UK, providing healthcare and social care organisations with flexible staffing solutions. We help our clients fill rota gaps through permanent staff, internal bank workers, or vetted agency workers. Our operations span workforce management technology, direct sourcing, agency collaboration, vetting, and payments to workers and agencies.
Our supply chain primarily includes:
- Health and care staffing agencies
- Technology providers (primarily top-tier, publicly listed firms)
We also operate under the trading names Digital Staff Solution Ltd (No. 10434349) and Florence Staffing Ltd (No. 12178272).
Policies Relating to Modern Slavery
Florence has implemented the following internal policies to combat modern slavery:
- Modern Slavery Policy: Outlines our commitment to preventing modern slavery and provides guidance on recognising and reporting risks.
- Supplier Code of Conduct: Requires our agency partners to uphold human rights, prohibit forced and child labour, and comply with relevant UK legislation.
- Whistleblowing Policy: Encourages employees and suppliers to report any concerns in confidence and without fear of retaliation.
High-Risk Areas in Our Business and Supply Chains
We recognise that all roles in healthcare carry some risk of exploitation, but we assess lower-paid roles, such as care assistants or support workers, as presenting the highest vulnerability to modern slavery. These roles are more likely to be filled by individuals who are not degree-educated and may face financial or immigration-related pressures.
In our supply chain, agency partners represent the most significant risk. We take extra steps to ensure they meet our ethical standards before engagement.
Due Diligence and Supplier Controls
All new agency suppliers must complete a comprehensive onboarding process, which includes confirmation of their compliance with our Modern Slavery Policy. Failure to complete this process in full results in disqualification from partnering with Florence.
We also:
- Audit selected agencies, prioritising those with higher perceived risks
- Conduct ongoing risk-based assessments of existing suppliers
- Include modern slavery compliance clauses in our standard contracts
- Maintain internal systems to track and categorise supplier risks
Training and Awareness
Florence provides modern slavery training to all staff during induction, with annual refresher training thereafter. We also routinely incorporate modern slavery discussions into broader business communications to reinforce awareness.
Staff involved in procurement, agency management, and compliance receive additional guidance to help them identify red flags and respond appropriately.
Monitoring and Key Performance Indicators
To measure our progress in tackling modern slavery, Florence is introducing a set of internal KPIs, including:
- % of agency suppliers completing modern slavery assessments during onboarding
- % of staff completing mandatory modern slavery training annually
- # of reports or concerns raised internally and outcomes
- # and frequency of audits conducted with agency suppliers
- Rate of non-compliance and corrective actions taken
These indicators will help us evaluate our efforts, strengthen accountability, and continuously improve how we protect vulnerable workers across our supply chain.
Ongoing Commitment and Next Steps
Florence will continue to:
- Strengthen due diligence processes with new and existing suppliers
- Raise awareness through targeted internal communications
- Refine tools to assess and monitor supply chain risk
- Protect whistleblowers and encourage the reporting of concerns
- Engage with industry partners to share and apply best practices
Approval and Sign-off
This statement was approved by the Executive Board Directors on 21/01/2024 and covers our financial year ending 31 December 2025.
Signed,
Charles Armitage
CEO
23/01/2025 (For Financial Year 2025)