Modern Slavery Statement.
This statement applies to Holmes Care Group Scotland Ltd. And subsidiary companies (‘Holmes Care Group’). The information included within the statement refers to the financial year September 2025 – August 2026.
Organisation and structure
Celebrating over 40 years in the care industry, Holmes Care Group is a multi-award-winning care group providing nursing, residential and specialist care. We have 23 services and are recognised in the industry for providing high quality and innovative facilities. Each resident is as important and individual to us as a loved one is to their family, we carefully select our employees based on their compassion, experience, expertise and, most importantly, their commitment and professionalism for providing the highest levels of care. Our workforce structure is designed to support safe, high‑quality care across our regional locations
Holmes Care Group employs approximately 1,500 people across multiple care homes located in Scotland and England. The company operates solely within the United Kingdom, with no overseas staff, operations, or supply‑chain activities outside the UK. Strategic oversight and governance are provided by a Board of Directors, who ensure the organisation is effectively managed and compliant with all relevant legislation. All services are delivered directly within the UK.
Our Commitment
This statement is made in accordance with Section 54 of the UK Modern Slavery Act 2015 and sets out the steps the Holmes Care Group has taken, and continues to take, to ensure that modern slavery or human trafficking is not taking place within our business operations or our supply chains.
The Holmes Care Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015 and has a zero-tolerance approach to modern slavery and human trafficking in all its forms, and in all the Company’s business dealings or supply chains. We understand this requires an ongoing review of both internal practices in relation to our labor force and, additionally, our supply chains.
The Holmes Care Group does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labor.
Due diligence and supply chains
The Holmes Care Group relies on local and global supply chains to help support the business. We ensure that suppliers perform in line with our expectations before being approved to join our preferred supplier list. We will conduct supplier reviews periodically, reviewing information returns and acting on any concerns that we identify.
We undertake consistent reviews of our labour standards to ensure our working practices remain fair, transparent, and fully compliant with UK legislation. All contracts of employment adhere to the Working Time Directive. We maintain a robust verification process to confirm the authenticity and compliance of right‑to‑work documentation for all employees. In addition, we operate structured monitoring and escalation procedures to identify, investigate, and address any potential risks within our workforce or recruitment processes.
Our policies and procedures
The Holmes Care Group operate a number of internal policies and procedures to ensure that we are conducting business in an ethical and transparent manner. Our policies are under constant review to ensure that we continue to be aligned to Holmes Care Group values and promote a workplace that is fair, open and transparent.
Our Grievance policy details how formal concerns can be raised and how they will be investigated and responded to.
Our Whistleblowing policy details the different whistleblowing pathways open to employees, should they have any concerns. Employees can raise concerns of any nature to their line manager, the CEO, the HR Director, or any member of the HR Team.
Our equal opportunities policy sets out our commitment to providing a fair, inclusive, and non-discriminatory working environment for all employees.
Our code of conduct policy sets out the standards of behavior expected from employees ensuring ethical, professional, and value’s led behavior.
Our Modern Slavery Policy outlines our commitment to preventing modern slavery, human trafficking, and any form of forced or exploitative labor within our Company or supply chains, ensuring we maintain the highest standards of ethical practice.
Our Recruitment policy ensures we continue to operate a robust recruitment process, including conducting eligibility to work in the UK checks for all staff, to safeguard against human trafficking or individuals being forced to work against their will.
All policies are available to all staff.
Risk management
We are committed to acting ethically and with integrity and transparency in all business dealings and by putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
We maintain robust recruitment and vetting processes designed to prevent any form of forced, bonded, or trafficked labour within our organisation or supply chain. All candidates undergo rigorous right‑to‑work checks, and we partner only with compliant recruitment agencies who meet our ethical standards.
There have been no disclosures or any identified instances of modern slavery within the Company to date. We also conduct payroll checks annually to ensure, in so far as possible that, that no employee is having their salary paid to someone else, against their wishes.
We are confident that should a disclosure be made, we have appropriate systems and processes in place to ensure corrective action is taken promptly.
Training
Our commitment to preventing modern slavery is strengthened by comprehensive training across the organisation. We are launching enhanced modern slavery training during the 2025–26 year, ensuring all colleagues understand the signs of exploitation and the steps to take if concerns arise. This complements our mandatory induction programme, which already includes ethical working practices and right‑to‑work compliance, as well as regular refresher training to maintain awareness. Managers receive targeted, role‑specific training to equip them to identify risks within their teams and supply chains, and clear guidance is available to all employees on how to report any suspected incidents promptly and safely.
Monitoring and evaluation
We are committed to continuously monitoring and evaluating the effectiveness of our measures to prevent modern slavery across our organisation and supply chain. This includes regular reviews of our recruitment, onboarding, and supplier‑management processes, alongside audits of right‑to‑work checks and training completion rates. We will analyse trends, investigate any reported concerns, and use findings to strengthen our controls and address emerging risks. Senior leaders will receive updates to ensure accountability, and our approach will be refined annually to reflect best practice and the evolving regulatory landscape.
Future actions
We remain committed to strengthening our approach to preventing modern slavery and will continue to enhance our policies, training, and oversight in the year ahead. A key priority for 2025–26 is the rollout of our new, enhanced modern slavery eLearning training program, which will improve awareness across the organisation and deepen understanding of how to identify and report risks. We will also continue to review our supplier‑due‑diligence processes, refine our internal controls, and embed system improvements that support more effective monitoring. These commitments reflect our determination to continuously develop our practices and maintain a proactive stance against all forms of exploitation.
Approval
This statement was approved by our board of Directors on 11th February 2026.
Name: Sharifa Lakhani, Chief Executive Officer
