PRIVATE THERAPY CLINIC LTD

Modern Slavery & Human Trafficking Statement

Published in accordance with the Modern Slavery Act 2015, Section 54

1. Introduction & Organisational Overview

Private Therapy Clinic Ltd is a UK-registered private mental health provider delivering psychiatric assessments, psychological therapy, and neurodevelopmental assessments (including ADHD and autism) to adults and children. Our services are delivered primarily via remote digital platforms, with selective in-person assessment provision at our UK premises and at partner clinical sites.

We operate as an independent provider and are registered with the Care Quality Commission (CQC). We also deliver services on behalf of NHS commissioners under different frameworks, including the Essex ICB Patient Choice Accreditation Framework (PCAF) and Right To Choose Framework (RTC).

We are committed to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking are not taking place anywhere in our operations or supply chains.

2. Our Structure, Business & Supply Chains

Organisational Structure

Private Therapy Clinic Ltd is a small-to-medium enterprise (SME) operating in the UK healthcare sector. We employ a small permanent administrative and management team, and engage clinical practitioners on a sessional, self-employed contractor basis. All practitioners are qualified, registered professionals subject to UK regulatory oversight (HCPC, RCPsych, NMC, BPS, BACP, BABCP, UKCP as applicable).

Our Supply Chain

Our supply chain is limited in scope and primarily involves:

• Clinical platforms and electronic patient record systems
• Secure digital communication tools (Google Workspace Enterprise)
• Professional indemnity and insurance providers
• Sessional clinical practitioners engaged as independent contractors
• Clinical venue hire at partner locations
• NHS commissioning bodies as commissioning clients

We do not procure physical goods, operate manufacturing processes, or engage in supply chains with significant modern slavery risk profiles. However, we recognise that risk is not zero in any supply chain and maintain appropriate due diligence accordingly.

3. Risk Assessment & Due Diligence

Risk Assessment

We have assessed the risk of modern slavery and human trafficking across our operations and supply chains. Key findings:

Due Diligence Processes

The following due diligence measures are in place:

• All clinical practitioners undergo pre-engagement checks including identity verification, professional registration confirmation, DBS enhanced disclosure, and right to work checks
• Self-employed practitioners sign contracts that include expectations of compliance with the Modern Slavery Act 2015
• New suppliers are assessed against basic compliance criteria including whether they are UK-regulated or subject to equivalent overseas standards
• We use established, reputable technology suppliers with published modern slavery and human rights policies
• Staff are trained to identify and report signs of exploitation through our Safeguarding Policy (P18) and Whistleblowing Policy (P21)

4. Policies Relevant to Modern Slavery

The following internal policies support our commitment to preventing modern slavery and exploitation:

• Equality, Diversity & Human Rights Policy (P08): explicitly references the Modern Slavery Act 2015 and our commitment to human dignity and freedom from exploitation
• Safeguarding Policy (P18): sets out our duty to identify and report exploitation of children and vulnerable adults
• Whistleblowing Policy (P21): provides staff with safe, protected channels to raise concerns about exploitation or misconduct
• Staff Training & Development Policy (P20): ensures staff are trained on safeguarding, including awareness of modern slavery indicators
• Recruitment and Pre-Employment Checks: all practitioners are subject to identity, registration, and right to work verification before engagement

5. Training & Awareness

All staff receive mandatory training in safeguarding, including awareness of modern slavery and human trafficking, as part of their induction and through annual refresher training delivered via Blue Stream Academy. Training covers:

• Recognising indicators of modern slavery and labour exploitation
• Understanding responsibilities under the Modern Slavery Act 2015
• Reporting procedures and escalation pathways
• The impact of exploitation on vulnerable individuals, including those with mental health conditions

6. Key Performance Indicators

We measure our progress against modern slavery commitments through:

• 100% completion of safeguarding and awareness training for all staff and new joiners
• Pre-engagement compliance checks completed for all clinical contractors prior to commencement
• Zero reported incidents of modern slavery or exploitation in our operations or supply chains
• Annual review of this statement and supporting policies

7. Our Commitment & Sign-Off

Private Therapy Clinic Ltd is committed to continuous improvement in our approach to preventing modern slavery and human trafficking. We will review this statement annually, respond to any concerns raised, and update our practices in line with legislative and regulatory developments.

This statement has been approved by Company Director and applies to all activities of Private Therapy Clinic Ltd for the financial year ended 30 November 2025.