Modern Slavery and Human Trafficking Statement
Sama Healthcare Limited | Financial year ended 30 June 2026
Organisation: Sama Healthcare Limited
Company number: 11407078
Registered office: CP House, Otterspool Way, Watford, Hertfordshire, WD25 8HR
Reporting period: 1 July 2025 to 30 June 2026
Publication basis: Voluntary statement. Sama falls below the £36 million threshold under section 54 of the Modern Slavery Act 2015, based on its most recent available accounts.
1. Our commitment
Sama Healthcare Limited does not tolerate forced labour, servitude, human trafficking or other exploitation. We want people working for us, and people receiving our services, to be safe from coercion, unlawful recruitment charges and abuse. We recognise that having a policy alone does not prevent exploitation. Staff must understand what to look for, feel able to report concerns and know that management will act.
Sama provides domiciliary and community-based care, including support to adults with complex needs. Its workforce includes employees recruited through routes that may involve immigration sponsorship. This can create particular risks of dependency and exploitation. Care workers may also encounter warning signs during home visits. Our main priorities are ethical recruitment, safeguarding, appropriate supplier checks and action when concerns are raised.
This is our first voluntary statement, prepared for the financial year ended 30 June 2026. It describes the company arrangements evidenced to date and identifies additional controls planned for 2026/27. It does not suggest that all planned checks have already been completed.
2. Our business and supply chain
Sama Healthcare Limited is a CQC-registered, nurse-led care provider operating in Hertfordshire and Buckinghamshire. It is managed by two directors with nursing backgrounds. Its care workforce is supported by care coordination, recruitment and management functions. Staff work in service users’ homes and in community settings, which makes both worker welfare and safeguarding important.
The main purchased goods and services used in delivering care include:
- Electronic care records and rostering, including PASS and Nourish, and recruitment administration through Atlas.
- Policy management and compliance support through QCS.
- Personal protective equipment, hygiene products and other care consumables.
- Staff training, recruitment checks and relevant professional services.
- Temporary or agency workforce services where such arrangements are used to maintain safe cover.
We recognise that risks may arise both in direct recruitment and further up suppliers’ labour chains, particularly in consumables manufacturing and labour intermediaries. We will give greater scrutiny to suppliers and recruitment routes with higher exposure rather than assume that purchasing in the UK removes the risk.
3. Policies and employment standards
Sama uses QCS to manage its policies and procedures. Its documented arrangements include safer recruitment, safeguarding, equality, staff induction, supervision, incident reporting and management oversight. These provide a basis for recognising and responding to exploitation. The company will consolidate its requirements on modern slavery and ethical recruitment into a dedicated policy during 2026/27.
Our employment and recruitment standards are that:
- Workers must not be charged prohibited employer sponsorship costs, including the Certificate of Sponsorship fee and Immigration Skills Charge, or subjected to unlawful recruitment charges.
- Original passports and identity documents are checked for legitimate purposes and returned; employees should keep control of their documents and personal bank accounts.
- Pay, working hours, deductions, notice periods and relevant rights must be explained clearly in employment documentation.
- Staff must be able to report concerns about working conditions, threats, coercion or abuse without retaliation, using management or whistleblowing routes.
These are the standards Sama is adopting for this statement. A review of current recruitment materials and sponsored-worker arrangements is included in the action plan so that actual practice and records can be checked against them.
4. Identifying and managing risk
For a care provider of Sama’s size, the following are the main foreseeable risks. This is an initial risk assessment based on the business model, not a claim that any of the incidents described has happened.
Sponsored and migrant workers
Why it matters: Dependency on a sponsor, recruitment debt, threats about immigration status or pressure to work extra hours.
Control or action: Review contracts and recruitment pathways; provide confidential reporting routes and check any recruitment charges.
Agency or intermediary labour
Why it matters: Less visibility of what workers were promised, charged or paid by another organisation.
Control or action: Apply documented checks if an intermediary or agency is used, including worker welfare and recruitment charges.
Service users in their homes
Why it matters: Financial exploitation, coercion, forced criminal activity or abuse by people in or around the household.
Control or action: Use existing safeguarding reporting and seek appropriate professional or statutory support promptly.
Consumables and supplies
Why it matters: Upstream forced labour risks may be hidden within manufacturing or distribution.
Control or action: Use proportionate supplier screening and record any concerns or follow-up decisions.
5. Due diligence and response
Recruitment and workforce checks
Sama’s recruitment arrangements include interviews, references, right-to-work and appropriate Disclosure and Barring Service checks, followed by induction and competency assessment. The checks required will match the role and applicable legal requirements. To strengthen modern slavery controls, recruitment staff will record whether an applicant has dealt with an intermediary, paid recruitment fees or experienced pressure about their documents, pay or accommodation. Any concern will be reviewed sensitively without placing the worker at further risk.
For sponsored staff, management will review the allocation of sponsorship costs, contractual deductions and any repayment provisions against current Home Office guidance. Where workers have used external recruitment agents, the company will examine any reported fees or debts and consider protective and remedial action. These targeted checks are planned improvements and are not presented as completed checks for every worker in 2025/26.
Suppliers and external workers
Sama will introduce a proportionate labour standards enquiry for suppliers that materially support care delivery. It will ask about lawful employment, recruitment charges, worker rights and how concerns are handled. Where agency workers are used, managers will check the agency’s arrangements and the worker’s suitability before deployment. Adverse responses will prompt follow-up, with decisions documented and contracts reviewed where necessary.
Raising a concern
Staff can raise concerns with a senior worker, the Registered Manager or a director. Concerns involving a service user will be managed through safeguarding arrangements, including referral to the relevant local authority safeguarding team where appropriate. Where there is immediate danger, emergency services will be contacted. Potential victims of modern slavery will be treated sensitively and their confidentiality protected.
For a suspected adult victim, Sama will seek advice from an appropriate designated first responder organisation, such as the local authority or police, so a National Referral Mechanism referral can be considered. An adult’s informed consent is required for an NRM referral. Where an adult does not consent, the designated body will consider any applicable Duty to Notify requirements. Sama will not claim to submit NRM referrals independently unless it has designated first responder status.
6. Training and awareness
Sama’s current workforce arrangements include safeguarding training, induction, supervision and incident reporting. These support staff in recognising abuse but do not, by themselves, demonstrate completion of specialist modern slavery training. The training matrix and supervision records will be used to monitor this.
During 2026/27, modern slavery awareness will be added to induction and safeguarding updates. Topics will include forced labour indicators, debt and recruitment fees, sponsored-worker rights, exploitation within service users’ homes and safe reporting. Staff who recruit or supervise sponsored workers will receive additional guidance. Completion will be tracked and discussed during supervision or management review.
7. Monitoring effectiveness
This is the first year of voluntary reporting, and a reliable trend cannot yet be shown. The indicators below will be collected and reviewed during 2026/27; no figures are reported as zero without records to support them.
Pre-employment checks completed before relevant duties
Evidence to retain: Personnel file audit: right to work, references and relevant DBS checks.
Review: Quarterly.
Recruitment, fee or sponsorship concerns and resulting action
Evidence to retain: Recruitment concerns log and management decisions.
Review: Quarterly.
Safeguarding or whistleblowing concerns involving suspected exploitation
Evidence to retain: Restricted incident or safeguarding log; statutory referrals if made.
Review: Quarterly.
Staff completing modern slavery awareness learning
Evidence to retain: Training matrix, attendance and competency checks.
Review: Six-monthly.
Material suppliers screened and outstanding concerns
Evidence to retain: Supplier register, questionnaires and follow-up record.
Review: Annually.
Use of agency or intermediary workers and checks completed
Evidence to retain: Staffing/recruitment and supplier records, if used.
Review: Quarterly.
The directors will review findings, ensure that actions have owners and deadlines, and include a factual progress summary in the next statement. Records that do not yet exist will be introduced rather than assumed.
8. Actions for 2026/27
Action 1: Approve a modern slavery and ethical recruitment policy, including recruitment cost and worker welfare standards.
Responsible role: Director responsible for governance.
Target: 31 March 2027.
Action 2: Review sponsored-worker contracts and recruitment routes for prohibited cost recovery, undue deductions and debt-related concerns.
Responsible role: Director responsible for governance.
Target: 31 January 2027.
Action 3: Include modern slavery risks, worker rights and referral routes in induction and safeguarding refresher content.
Responsible role: Registered Manager.
Target: 30 June 2027.
Action 4: Brief all staff involved in recruitment on sponsorship risks and worker welfare checks.
Responsible role: Registered Manager.
Target: 30 June 2027.
Action 5: Introduce a proportionate labour standards enquiry for material suppliers.
Responsible role: Director responsible for operations.
Target: 30 September 2027.
Action 6: Create an evidence-based KPI and action register and review it at director level.
Responsible role: Registered Manager and directors.
Target: First review: 30 June 2027.
9. Approval and publication
This statement has been prepared for review and adoption by the board of directors of Sama Healthcare Limited. It must not be described as board-approved, signed or published until those steps have taken place. Following approval, the signed statement will be published on the company website, with a clear link from the homepage. Sama may also choose to add it to the Government Modern Slavery Statement Registry, which is voluntary.
Director’s name: ENIKA CHASAFARA
Date: 3 November 2026
References:
Modern Slavery Act 2015, section 54; Home Office, Transparency in Supply Chains: a Practical Guide (2025); Home Office guidance on the National Referral Mechanism for adults (2026).
