Modern Slavery Act 2015 - Section 54 Statement
Introduction
Moran Health Consulting Ltd is committed to conducting business ethically, transparently and responsibly. We recognise that modern slavery, forced labour, human trafficking and other forms of exploitation can occur in organisations and supply chains of any size.
Moran Health is not currently required by section 54 of the Modern Slavery Act 2015 to publish a modern slavery statement because its turnover is below the statutory threshold. We nevertheless publish this statement voluntarily as part of our commitment to responsible business, ethical procurement and proportionate public-sector assurance.
This document combines Moran Health’s Modern Slavery Statement with its Ethical Procurement Policy. It is intended to explain our organisation and supply chains, the risks we consider, the controls we apply, how concerns can be raised and how we intend to measure and improve our approach.
Modern Slavery Statement
1. Organisation and supply chains
Moran Health Consulting Ltd is a UK-based, founder-led specialist health and care consultancy. Our work includes population health and equity, digital and data strategy, performance and improvement, health economics and outcomes, and leadership and capability support.
Moran Health operates through a small core business supported, where appropriate, by specialist associates, subcontractors, advisers, suppliers and delivery partners. External capability is brought into defined roles and is subject to proportionate assurance and governance.
Our principal supply-chain relationships may include:
• specialist associates, subcontractors and professional advisers;
• software, data, cloud, communications and other digital service providers;
• accountancy, insurance, banking and other professional services;
• office equipment, technology hardware, travel and related business services; and
• specialist suppliers or delivery partners engaged for individual client assignments.
Moran Health does not manufacture physical goods and does not operate a large, complex or labour-intensive supply chain. This reduces, but does not remove, potential exposure to modern slavery risk.
2. Commitment and related policies
Moran Health has zero tolerance for modern slavery, forced labour, child labour, human trafficking or exploitation in its own operations or supply chains. We expect anyone working under, with or on behalf of Moran Health to act lawfully, ethically and with respect for human rights.
Our approach is supported by related Moran Health governance, including our Associate and Partner Standards Statement, supplier and partner assurance arrangements, contractual controls, good-faith concern and complaints routes, and wider ethical procurement expectations.
We expect suppliers, subcontractors and associates to:
• comply with applicable employment, labour, equality, health and safety and human-rights law;
• not use forced, trafficked, bonded or child labour;
• maintain appropriate employment and working practices;
• raise concerns where they identify unsafe, unlawful or unethical conduct;
• cooperate with proportionate due diligence and assurance requests; and
• address identified concerns promptly and transparently.
Related policies, agreements and records
This policy should be read alongside Moran Health’s related controls:
• for supplier selection, vetting, supply-chain risk and monitoring, see the Supply Chain Management Policy and Supplier and Partner Assurance;
• for associates, subcontractors, onboarding and contractual expectations, see the Associate and Partner Standards Statement and Supply Chain and SubContractor Agreement;
• for fair work, worker voice and freedom of association, see the Fair Work Policy and Supplier Union Recognition and Worker Representation Policy;
• for prompt and fair payment, see the Supply Chain Payment Policy;
• for concerns, escalation, investigation and complaints, see the Accountability, Challenge and Complaints Process;
• for supply-chain mapping, supplier and associate due diligence, purchasing-practices assessment and corrective actions, see the Moran Health Supplier & Associate Assurance Register; and
• for assurance evidence and improvement actions, see the Moran Health Evidence and Assurance Register.
Worker protection standards
Moran Health requires its own practices and, where relevant and proportionate, its suppliers, subcontractors, associates and partners to uphold the following minimum worker protections:
• adherence to applicable local and national employment, labour, equality and human-rights laws;
• workers must be free to terminate their employment or engagement in accordance with lawful notice requirements and must not be prevented from leaving through threats, withheld wages, deposits, debt or other coercive penalties;
• workers must have freedom of movement and must not be physically confined, unlawfully restricted or prevented from leaving the workplace or accommodation;
• workers must be free to exercise lawful rights of freedom of association and collective representation;
• violence, threats of violence, harassment, intimidation, abuse or other coercive treatment are prohibited;
• workers must not be charged recruitment, placement or similar fees as a condition of obtaining work. Where worker-paid recruitment fees connected with an engagement are identified, Moran Health expects the responsible organisation to provide appropriate reimbursement or remediation;
• compulsory overtime is prohibited. Working hours and overtime must comply with applicable law and workers must not be forced to work overtime through threat, penalty or coercion;
• child labour is prohibited. Suppliers must comply with applicable minimum-age and young-worker protections;
• discrimination in recruitment, employment, pay, treatment or access to opportunity on unlawful grounds is prohibited;
• workers’ original passports, identity documents, work permits or other personal documents must not be confiscated or withheld as a means of control. Where documents are temporarily held for a legitimate administrative reason, this must be lawful, transparent, time-limited and the worker must retain appropriate access; and
• anyone affected by modern slavery or exploitation must not be obstructed from accessing appropriate remedy, compensation, support, legal rights or justice. Moran Health expects relevant suppliers and partners to cooperate with lawful investigations and remediation.
These standards form part of Moran Health’s ethical procurement expectations. A breach may trigger investigation, corrective action, enhanced monitoring, suspension, referral to an appropriate authority or termination, depending on the circumstances.
3. Risk assessment and highest-risk area
Moran Health assesses its overall direct modern slavery exposure as relatively low because its principal activities are professional, knowledge-based services. We do not, however, regard the risk as zero.
Areas of comparatively greater potential exposure include:
• subcontracted or outsourced labour where working conditions are less visible to Moran Health;
• technology hardware and electronics supply chains, which may involve complex international manufacturing tiers;
• labour-intensive ancillary services, if procured, such as facilities, logistics or similar services;
• suppliers or partners operating in jurisdictions or sectors associated with weaker labour protections or higher prevalence of exploitation; and
• multi-tier subcontracting arrangements where Moran Health has less direct oversight of the people undertaking the work.
Risk is considered proportionately according to the nature of the service, location of delivery, labour model, use of subcontracting, degree of supply-chain visibility and potential impact on workers.
Supply-chain mapping and current operating position
Moran Health maintains a Supplier & Associate Assurance Register that combines its Tier 1 supply-chain map, supplier and associate assurance record, purchasing-practices assessment and corrective-action log. The map is informed by accounting records, operating systems and known business relationships and is updated when a material supplier, associate or subcontractor is appointed or the delivery model changes.
As at 25 September 2026, Moran Health has no employees and has not engaged delivery associates or subcontractors. The current supply-chain map therefore focuses on direct operational and platform suppliers and records future delivery relationships as a pre-engagement control rather than presenting supplier checks that have not occurred.
For large standard-form technology or platform providers, Moran Health records available public modern-slavery and human-rights evidence, relevant supplier codes, known delivery geography and supply-chain complexity, together with the degree of leverage Moran Health has over the relationship. Moran Health does not claim to audit or control the workforce practices of such providers. Lower supply-chain tiers will be mapped where they are visible and where the nature of the relationship, subcontracting, geography, worker exposure or identified risk warrants further investigation.
4. Due diligence and supplier management
Moran Health applies proportionate due diligence to material suppliers, associates, subcontractors and partners. The level of assurance is based on the nature and risk of the relationship rather than applying the same process to every purchase.
Depending on the role and risk, due diligence may include:
• confirming supplier or contractor identity and business status;
• considering where and how services are delivered and whether subcontracting is involved;
• reviewing relevant policies, certifications, modern slavery statements or equivalent evidence where appropriate;
• requiring compliance with Moran Health’s ethical, legal and contractual expectations;
• seeking additional information where a relationship presents a higher modern slavery or labour-risk profile; and
• monitoring concerns, performance or material changes during the relationship.
Where a material concern is identified, Moran Health may seek further evidence, require corrective action, increase monitoring, suspend work or terminate the relationship where appropriate.
5. Training and awareness
Moran Health takes a proportionate approach to training and awareness. As a founder-led business, we do not operate a large permanent workforce requiring a corporate training programme.
The Director maintains awareness of modern slavery obligations and good practice through relevant government guidance, procurement requirements and the Modern Slavery Assessment Tool. Where employees, associates, subcontractors or other personnel are engaged in roles where modern slavery or labour-risk awareness is relevant, Moran Health will provide appropriate briefing, guidance or training on:
• recognising indicators of exploitation;
• Moran Health’s ethical and supplier expectations;
• how to raise a concern; and
• the responsibility to escalate suspected unlawful or unethical conduct.
Moran Health has selected the free Protecting Human Rights in the Supply Chain eLearning suite developed by the London Universities Purchasing Consortium (LUPC), University of Greenwich and APUC as its core modern slavery and supply-chain training resource. Training will also include review of the International Labour Organization (ILO) Indicators of Forced Labour so that relevant personnel understand the principal warning signs of forced labour and how these should inform due diligence, escalation and supplier management.
On 25 September 2026, Andrew Moran, Director and Chief Executive Officer, completed and passed the LUPC, University of Greenwich and APUC Protecting Human Rights in the Supply Chain eLearning suite. This is recorded as completed senior-management training and will inform Moran Health’s procurement, supplier-assurance and modern-slavery due-diligence activities.
On the same date, he completed a review of the ILO 2025 revised Indicators of Forced Labour. Moran Health records the 11 indicators and organisation-specific warning-sign examples in its Supplier & Associate Assurance Register for use in supplier screening, enhanced due diligence and investigation of concerns.
Policy communication, training and capacity building
This policy is approved by Moran Health’s Director and Chief Executive Officer and forms part of the organisation’s governance framework.
Moran Health will make this policy and the standards it contains available to relevant employees, associates, subcontractors and suppliers. Where a person joins Moran Health or is engaged in a role involving procurement, supplier management or a material supply-chain risk, the policy will be provided or signposted as part of onboarding, mobilisation or engagement.
Relevant staff, associates and subcontractors whose roles involve procurement, supplier management or heightened modern slavery risk must receive proportionate briefing, guidance or training appropriate to their responsibilities. This may include recognising indicators of exploitation, applying due diligence, escalating concerns and understanding Moran Health’s worker-protection standards.
Suppliers assessed as presenting a heightened modern slavery risk must be informed of the applicable policy requirements. Where Moran Health has a direct engagement and contractual leverage, the supplier must complete relevant modern-slavery training or provide evidence of equivalent training and controls appropriate to the identified risk. For large standard-form platform providers where Moran Health cannot reasonably impose bespoke workforce training, Moran Health will instead review available modern-slavery and human-rights evidence, supplier codes and other published assurance information, record the limits of its leverage, and reconsider the relationship if material concerns cannot be adequately addressed.
Moran Health will retain proportionate evidence of policy communication, briefings and training where these activities occur.
6. Reporting concerns and remediation
Employees, associates, subcontractors, suppliers, partners and other stakeholders may raise a good-faith concern directly with the Chief Executive Officer or through Moran Health’s established accountability, challenge and complaints routes.
Moran Health will not penalise a person for raising a genuine concern in good faith. Concerns will be considered proportionately and confidentially where possible.
Where modern slavery or exploitation is suspected, Moran Health will prioritise the safety and welfare of affected people, investigate the concern, seek appropriate specialist or legal advice where required, work with relevant parties on remediation and notify appropriate authorities where there is a legal or safeguarding requirement to do so.
Termination of a supplier relationship may be appropriate in serious cases, but Moran Health will consider whether immediate termination could worsen the position of affected workers and will take a proportionate, person-centred approach.
Supplier corrective action plans
Where a material modern slavery or labour concern involves a supplier, associate or subcontractor, Moran Health will, where this is within its contractual relationship or available leverage, require a documented corrective action plan. The plan must record the concern or gap, impacts on workers, root cause, corrective action, responsible owner, deadline, milestones or targets, supplier response, measures to prevent recurrence and evidence of closure. Actions will be tracked in the Moran Health Supplier & Associate Assurance Register and reviewed until resolved or escalated. The safety, welfare and remedy of affected workers will remain the primary consideration.
7. Measuring effectiveness and key performance indicators
Because Moran Health is at an early stage of developing its supply-chain assurance arrangements, the following measures are adopted as 2026/27 targets rather than presented as historic performance:
• 100% of new material associates, subcontractors and higher-value or higher-risk suppliers to receive proportionate ethical procurement screening.
• 100% of relationships identified as presenting a heightened modern slavery risk to receive enhanced due diligence.
• 100% of confirmed modern slavery or exploitation concerns to be recorded, investigated and subject to a documented response.
• Ethical and modern slavery obligations to be included in relevant supplier and subcontractor arrangements where proportionate to the engagement.
• Modern slavery risks and this statement to be reviewed at least annually.
• The Modern Slavery Assessment Tool to be reviewed at least annually, with relevant recommendations considered and actions recorded.
• Relevant employees, associates or subcontractors to receive an appropriate briefing or training where their role or the supply-chain risk warrants it.
These measures will be reviewed in future statements so that Moran Health can report progress and strengthen its approach as the organisation and its supply chain grow.
8. Governance and annual review
Responsibility for this statement and policy sits with the Director and Chief Executive Officer of Moran Health Consulting Ltd.
The statement will be reviewed at least annually and sooner where there is a material change in Moran Health’s business model, workforce, supply chain, operating geography or risk profile. Future versions will report on progress against the measures set out above.
Ethical Procurement Policy
9. Purpose
Moran Health’s Ethical Procurement Policy is intended to ensure that purchasing and supply-chain decisions support lawful, fair, transparent and responsible business practices. Ethical procurement includes, but is not limited to, preventing modern slavery and exploitation.
10. Ethical procurement principles
Compliance with law and ethical standards
Suppliers and contractors are expected to comply with applicable laws and standards relating to employment, labour rights, equality, health and safety, data protection, anti-bribery, modern slavery and other requirements relevant to the services they provide.
Fair work
Moran Health supports fair employment practices. We expect suppliers to avoid exploitative employment practices and to provide lawful and fair terms and conditions. Moran Health supports payment of the Real Living Wage where applicable and proportionate.
Purchasing practices and supplier pressure
Moran Health assesses whether its own purchasing practices could create pressures that increase modern slavery or labour-exploitation risk. The Purchasing Practices Assessment within the Moran Health Supplier & Associate Assurance Register considers pricing and associate fees, payment terms, lead times, scope changes, forecasting and capacity planning, cancellation, penalties, specification clarity and working-hours pressure.
Moran Health’s controls include agreeing rates and scope before engagement, paying valid and undisputed invoices within agreed terms, normally within 30 days, setting realistic delivery times, agreeing material scope changes and associated time or fees, avoiding compulsory overtime and not imposing unfair penalties. The assessment is reviewed at least annually and when Moran Health first appoints, or materially changes its relationship with, an associate, subcontractor or delivery supplier.
Transparency and accountability
Suppliers should be open about material subcontracting and should provide reasonable evidence of compliance with ethical requirements where requested. Moran Health expects concerns or breaches to be disclosed promptly rather than concealed.
Proportionate supplier assurance
Assurance requirements will reflect the nature, value and risk of the engagement. Moran Health will avoid unnecessary burdens on micro, small and medium-sized enterprises while maintaining appropriate protections for workers, clients and the public.
Supplier evidence and purchasing decisions
Moran Health considers the quality and transparency of a supplier's published modern slavery, human rights, labour and supply-chain assurance when selecting, renewing or materially expanding supplier relationships. Where credible comparable alternatives are available, Moran Health may prefer suppliers able to evidence stronger controls and transparency. A lack of published evidence is not treated as proof of non-compliance; it may result in further due diligence, limits on new dependency or planned migration where this better supports Moran Health's standards, continuity and value.
Collaboration and improvement
Where concerns can be remedied safely and appropriately, Moran Health will seek improvement as well as compliance. We may work with suppliers and partners to strengthen standards, share guidance and address identified gaps.
Sustainability and social value
Where relevant to the procurement, Moran Health will also consider environmental sustainability, responsible business conduct, social value and alignment with our wider organisational values.
11. Supplier selection, contracts and monitoring
Moran Health will take ethical procurement considerations into account when selecting and managing suppliers, subcontractors and partners.
Procurement lifecycle controls
Modern slavery risk will be considered proportionately throughout the procurement and supplier-management lifecycle:
• Needs identification — consider whether the proposed purchase, service, labour model, sector, location or delivery approach could create or increase modern slavery risk.
• Requirement definition — include appropriate ethical, labour and modern slavery requirements in specifications, scopes of work and supplier expectations.
• Tender evaluation — consider relevant modern slavery evidence, supplier policies, due diligence responses and risk factors when evaluating suppliers where proportionate.
• Contract award — ensure higher-risk suppliers accept applicable modern slavery and worker-protection requirements, or provide documented equivalent assurance, before engagement.
• In-life contract management — monitor material risk changes, concerns, subcontracting, performance and compliance and require corrective action where needed.
• End-of-contract review — consider any modern slavery concerns, incidents, supplier performance and lessons learned before closure, renewal or future re-engagement.
For suppliers assessed as presenting a heightened modern slavery risk, adherence to these standards, or demonstrably equivalent standards, is a condition of engagement. Moran Health will document any proportionate alternative assurance where standard supplier terms prevent direct contractual incorporation.
Relevant contractual arrangements may include requirements relating to lawful employment, modern slavery, ethical conduct, audit cooperation, information provision, reporting concerns and corrective action.
Supplier performance and compliance will be reviewed proportionately to the nature and risk of the relationship. Material breaches may result in corrective action, enhanced monitoring, suspension or termination.
12. Continuous improvement
Moran Health will continue to develop its ethical procurement and modern slavery controls as the organisation grows. We will use experience from procurement, client requirements, the Modern Slavery Assessment Tool, supplier assurance activity and relevant government guidance to improve this policy over time.
Approval and publication
This 2026 statement and policy is prepared for approval by the Director of Moran Health Consulting Ltd before publication.
Approved by: Andrew Moran, Director and Chief Executive Officer
Approval date: 01/04/2026
Conclusion
Moran Health Consulting Ltd is committed to responsible business and to reducing the risk of modern slavery and exploitation in its operations and supply chains. Our approach is proportionate to the size and nature of the organisation while recognising that small organisations still have a responsibility to understand risk, act where concerns arise and improve their controls as they grow.