Modern slavery statement 2026

HCA Healthcare has been providing healthcare in the United States for more than 50 years. In 1995, HCA entered the UK healthcare market through HCA UK and has built a network of over 30 facilities in London, Manchester and Birmingham.

Has HCA UK's position on modern slavery changed during the year?

No, HCA UK remains committed to promoting environments that are free from human trafficking, forced labour and unlawful child labour. To permit any deviation from this position would not only be unethical, it would detract also from our mission statement, which states that: Above all else, HCA UK is committed to the care and improvement of human life.

HCA UK recognises that our moral obligation to the communities in which we serve means that we must lead by example across the healthcare sector in promoting and enforcing a zero-tolerance approach. We commit to promoting a culture at our hospitals and healthcare facilities that encourages the prompt reporting and investigation of concerns about the welfare of any patient, family member or guest.

We also recognise the need for diligence within our supply chain (which is primarily UK-based but can extend globally). HCA UK reaffirms that we will not tolerate slavery, servitude, forced or compulsory labour in the manufacture of products and services that we use or sell; and we will not partner with suppliers which employ or utilise slavery, servitude, forced or compulsory labour in any manner.

In line with updated UK Government expectations published in 2025, HCA UK reaffirms its commitment not only to stating its position on Modern Slavery, but to showing how these commitments are implemented and reviewed in practice.

How does HCA UK train colleagues about modern slavery and indentured labour?

HCA UK recognises that in healthcare, Modern Slavery can manifest in a variety of ways, including the conduct, words and appearance of our patients and our patient’s carers. Not least because our clinical colleagues may be exposed to examples of Modern Slavery, we make this topic a key part of our Ethics and Compliance Programme, which has the strapline: ‘Enabled, Transparent and True’.

Annual ethics and compliance training is mandatory for all our permanent colleagues, as well as many of our contractors, physician and bank colleagues. We make a commitment every year to ensure that this training draws explicit attention to the zero-tolerance approach towards Modern Slavery set out above. We remind colleagues of the typical signs of indentured labour. We remind all our colleagues of this online statement, and we explain why we do this – including referencing the wider themes contained within the Modern Slavery Act 2015.

Attention is drawn to our policies and supporting procedures which set out the obligations on colleagues, management and our supply chains to report concerns about slavery and human trafficking without delay. In particular, HCA UK’s Speaking Up Policy reminds colleagues about the various ways in which concerns about unethical behaviours (including Modern Slavery) can be raised without fear of reprisals, including directly to our Freedom to Speak Up Guardian, our network of Speaking Up Champions at hospitals, sites and facilities, or via HCA’s Ethics Line which allows anonymous reporting. We support the work of the National Guardian and contribute our data to the National Guardian’s office for aggregation across the healthcare sector.

Where appropriate, the Freedom to Speak Up Guardian will involve the local Chief Nursing Officer and designated Safeguarding leads at our hospitals in reviewing reports which are made in good faith. Nobody who reports a concern they hold in good faith will suffer any detriment at work for speaking up.

In addition to mandatory annual training for all HCA UK colleagues, leaders in our business additionally receive bespoke learning which is tailored to their role and responsibilities in the business. This is refreshed every year to reflect current compliance and ethics trends in HCA UK’s business, sector and in the communities in which we operate. We make a commitment to keeping our leaders updated on relevant cases, law and best practice relating to Modern Slavery and human trafficking.

We have continued to embed our whole organisation Visitor Policy that includes clear expectation guidance regarding the family-employed staff or carers who accompany our patients to hospital. This is available in multiple languages and enables us to raise any concerns about possible domestic servitude with the carer as well as promoting patient safety.

In line with the March 2026 update to statutory guidance for England and Wales, HCA UK continues to strengthen trauma-informed practice and safeguarding awareness across clinical teams, reflecting new government emphasis on multiagency working, survivor vulnerability, and minimum standards of care for potential victims.

How does HCA UK work with its supply chain to identify concerns about modern slavery?

HCA UK is committed to promoting ethical and lawful employment and supply chain practices, and so our zero-tolerance approach to Modern Slavery extends to our suppliers, sub-contractors and business partners worldwide too. We require our suppliers to support our mission, and our core values of honesty, integrity and fairness. This is critical to fulfilling our mission and maintaining a healthy work environment.

Given our size and the range of specialisms in which we lead, we naturally buy a wide range of goods and services both in the provision and enabling of healthcare to our customers and to support our routine business. This can create complex supply chains, and so we must rely also on our suppliers taking this matter seriously too. Therefore, our diligence processes include testing that our suppliers are similarly committed to combating Modern Slavery and human trafficking in their own businesses, and we reserve the right to ask for further information to verify the accuracy of information provided.

Reflecting the updated 2025 transparency guidance, HCA UK continues to strengthen our supplier assessment processes, including clearer expectations for visibility beyond tier-1 suppliers, and we will disclose where further supply chain mapping is in progress.

What steps has HCA UK taken in 2025?

To demonstrate leadership in this area throughout our business, in the last year, HCA UK has taken the following steps.

A review of the Human Trafficking Policy. The correct name for this is now the Anti-Slavery Policy. This ensures the focus is on Modern Slavery in all its form and is more accessible and easier for others to understand. Work continues in relation to due diligence and will be reflected in the policy as it continues to be reviewed.
HCA UK’s Modern Slavery Working Group continues to meet regularly to discuss how we can identify and safely resolve concerns we have about Modern Slavery, always re-affirming that HCA UK is committed to promoting environments that are free from human trafficking, forced labour and unlawful child labour. Its membership has expanded and is made up of experts from various parts of the company, including nursing, HR, legal, political, sustainability and contracting. The group discusses how we can identify and safely resolve concerns and questions about Modern Slavery.
HCA UK is represented at the London Bi-Borough Modern Slavery and Exploitation Working Group. Made up from the boroughs of Westminster and Kensington and Chelsea, it is a multi-agency working group formed to enhance safeguarding practice in relation to Modern Slavery and domestic servitude. It is an opportunity to share good practice, inform education and training opportunities and create an established professional network.
There was a review of HCA UK’s safeguarding policies to ensure that there are clear pathways for escalation of concerns regarding Modern Slavery and domestic servitude.
We continue to focus on the topic of Modern Slavery in the mandatory training packages within our Ethics & Compliance syllabus, which is mandatory for all HCA UK colleagues. The topic features, for example, in our Ethics Leaders training video, which is a panel discussion amongst HCA UK’s senior leaders which is made available to around 400 senior colleagues.
We are undertaking a programme of work to improve our approach to Modern Slavery in our supply chain. We are doing this specifically by developing a Modern Slavery strategy and risk-based framework for supplier engagement, and integrating with good practice in the public sector to harmonise and coordinate supplier asks across the health system. The Modern Slavery Working Group continues to keep this under review to ensure that HCA UK’s responses are correct and consistent.

What will HCA UK be doing in 2026?

HCA UK will continue to develop our processes, policy and reporting lines around Modern Slavery. In particular:

The Modern Slavery Group will continue to meet. Each member of the group will play an active role in driving our programme forward – drawing on their specialist expertise to challenge assumptions, surface risks, and ensure that key questions and concerns around Modern Slavery are rigorously examined and addressed across all areas of HCA UK’s operations.
As part of the review of Code of Conduct and Supplier Due Diligence questions, Q&A guidance will be made available to colleagues to ensure HCA UK’s responses are correct and consistent.
In 2026, the Safeguarding Team will continue to ensure that colleagues feel empowered to recognise and respond to signs of Modern Slavery and domestic servitude through enhanced training, accessible escalation pathways, and proactive engagement with both internal and external partners. We will strengthen our approach to learning from safeguarding cases, ensuring that all actions taken reflect a trauma‑informed and person‑centred response.
The UK government increasingly expects companies to integrate environmental sustainability into their Modern Slavery Due Diligence. HCA UK will continue to strengthen its approach by embedding environmental sustainability risk factors proportionately into its due diligence process.
We will also adopt reforms announced by the UK government that take effect this year, including the introduction of mandatory reporting across all six areas, new board level personal signoff requirements, a single government registry with a fixed filing deadline, and the possibility of unlimited fines for insufficient or late statements.

Who takes responsibility for HCA UK's modern slavery programme, including this statement?

HCA UK employs a Director of Ethics and Compliance and Freedom to Speak Up Guardian who is responsible for the delivery of our Ethics and Compliance Programme, including the promotion of HCA UK’s speaking up programme. HCA UK ensures there are dedicated and named safeguarding leads at each hospital and healthcare facility. Accountability for the prevention of Modern Slavery rests with HCA UK’s leadership team who have overall responsibility for this statement and for ensuring that policy, internal systems and controls are kept under continuous review.

HCA UK’s Ethics and Compliance Programme reinforces the values set out in our Code of Conduct, which you can view at this page. The Code of Conduct emphasises the shared common values and culture that guide our actions: we act with absolute honesty, integrity and fairness in the way we conduct our business, and we pledge to treat all our colleagues, our customers with loyalty, respect and dignity.

To reflect evolving government expectations, future statements we publish will include more structured evidence of risk assessments, due diligence activities, outcomes, and continuous improvements, all which will be consistent with emerging UK reporting standards.

We expect to update this annual statement next in April 2027.

This statement is approved by the Board of HCA International Limited and is signed by HCA UK’s President and Chief Executive Officer.

John Reay headshot and signature

April 2026

HCA International Limited (also referred to as “HCA Healthcare UK”, “HCA” and “HCA UK”) is a private limited company registered in England and Wales with registration number: 03020522. The registered office is situated at 2 Cavendish Square, London, W1G 0PU. Unless we say otherwise, we use the terms "HCA Healthcare UK", "HCA UK", "we", "our” and "us" to refer to HCA International Limited throughout our website.

HCA International Limited makes this statement to comply with s.54(6) of the Modern Slavery Act 2015 on behalf of itself and all its Group companies (collectively referred to as ‘HCA UK’ in this statement).This statement is made in April 2025 and is updated in this version to reflect our priorities in this area for 2025.

Any queries relating to this statement can be directed to our Ethics and Compliance Officer at this email address: ethicsandcompliance@hcahealthcare.co.uk