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Modern Slavery and Human Trafficking Statement

Financial Year Ending 31 December 2025 

Prima Healthcare Group has a zero-tolerance approach to modern slavery, human trafficking, forced labour and exploitation. We are committed to conducting business ethically, responsibly and with respect for human rights across our operations and supply chains. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken during the financial year ending 31 December 2025. 

Our Business and Supply Chains

Prima Healthcare is a UK-based manufacturer and global supplier of dental rotary instruments. We employ over 230 colleagues, operate production facilities in the United Kingdom, have a sales subsidiary in India, and work with joint venture partners in Brazil, Hong Kong and China. We manufacture over 50 million dental burs annually and supply customers in more than 90 countries. 

Our supply chain includes raw materials used in manufacturing, including tungsten carbide, steel and diamond materials, as well as packaging, logistics, freight, facilities services, IT, professional services and temporary labour providers. We recognise that our greatest exposure to modern slavery risk is likely to arise in lower-tier supply chains, outsourced services, labour-intensive activities and raw material sourcing from higher-risk jurisdictions. 

Governance and Policies

Responsibility for Prima Healthcare’s approach to modern slavery rests with the Board of Directors, with day-to-day responsibility delegated to the Executive Leadership Team. The Board reviews and approves this statement annually.

Our approach is supported by the following policies and controls: 

  • Anti-Slavery and Human Trafficking Policy 
  • Whistleblowing Policy 
  • Recruitment and Agency Labour Policy 
  • Equal Opportunities and Dignity at Work Policy 
  • Code of Business Ethics 
  • Supplier Code of Conduct 

These policies set the standards expected of colleagues, suppliers and business partners. They also provide routes for employees and other stakeholders to raise concerns, including through whistleblowing arrangements.

Due Diligence and Risk Management

We apply a risk-based approach to supplier due diligence. New and existing suppliers may be assessed by reference to country risk, sector risk, commodity risk, use of labour intermediaries, subcontracting arrangements and the nature of the goods or services supplied.

During 2025, we continued to use supplier questionnaires, ethical policy reviews, supplier engagement and audit activity to identify potential gaps and improve supplier awareness. Where issues or weaknesses are identified, our preference is to engage constructively with suppliers and seek improvement, while reserving the right to suspend or terminate relationships where serious concerns are not addressed.

We consider the following areas to present heightened risk: 

  • Raw materials sourced from regions with weaker labour protections 
  • Outsourced services such as cleaning, logistics and security 
  • Contract, agency or temporary labour arrangements 
  • Lower-tier suppliers where visibility may be limited 

Measuring Effectiveness

We monitor the effectiveness of our approach through supplier assessment activity, audit outcomes, completion of supplier questionnaires, training completion, supplier engagement, improvement actions and any reports raised through whistleblowing or grievance channels.

During 2025, Prima Healthcare: 

  • Launched its Supplier Code of Conduct 
  • Continued supplier risk assessments across critical suppliers 
  • Conducted gap analysis based on supplier questionnaire responses 
  • Reviewed supplier ethical policies and procedures 
  • Maintained supplier audit and re-approval processes 
  • Delivered modern slavery training to the UK Senior Leadership Team 
  • Maintained modern slavery awareness materials for colleagues 

No confirmed instances of modern slavery or human trafficking were identified within Prima Healthcare’s own operations during the reporting period. Where concerns arise, we will prioritise the safety and wellbeing of affected individuals and work with appropriate authorities or specialist organisations as required.

Training and Awareness 

Modern slavery awareness forms part of our compliance training programme. During 2025, colleagues completed the online “Business Compliance – Modern Slavery” module, and additional training was delivered to the UK Senior Leadership Team covering modern slavery indicators, supplier due diligence expectations and escalation procedures. 

Further Steps 

In 2026, Prima Healthcare will continue to strengthen its approach by: 

  • Continuing the roll-out and enforcement of the Supplier Code of Conduct 
  • Further developing supplier risk assessment and monitoring 
  • Conducting additional supplier audits where risk assessments indicate heightened concern 
  • Strengthening reporting and grievance mechanisms 
  • Reviewing training and awareness materials 
  • Continuing to work with suppliers to improve labour standards and ethical practices 

Approval

This statement has been approved by the Board of Directors of Prima Healthcare Group and signed on its behalf by: 

Dan Hodgson
Chief Executive Officer
For and on behalf of Prima Healthcare Group

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