Modern Slavery & Human Trafficking Statement

This statement is made voluntarily by Virtual Pharmacist Ltd (company number 13258094) in respect of the financial year ending 31 March 2026. Whilst the Company is not legally required to produce a statement under Section 54(1) of the Modern Slavery Act 2015, as its annual turnover does not meet the statutory threshold of £36 million, Virtual Pharmacist Ltd recognises its responsibility as an NHS healthcare service provider to demonstrate its commitment to preventing modern slavery and human trafficking in all its forms.

This statement is published voluntarily to align with NHS procurement standards and the expectations of the NHS Standard Contract 2025/26, including Section 19 which addresses modern slavery requirements, and to demonstrate transparency in the Company’s business practices and supply chains.

1. About Our Organisation

Virtual Pharmacist Ltd is a UK-based professional services company providing fully managed remote clinical pharmacist services to GP Practices, Primary Care Networks (PCNs), and Integrated Care Boards (ICBs) across England. The company was incorporated on 10 March 2021 and is registered at Queen Street Chambers, 68 Queen Street, Sheffield, South Yorkshire, S1 1WR.

Services include Structured Medication Reviews, chronic disease management, high-risk medication monitoring, Quality and Outcomes Framework (QOF) support, prescribing support, and medication reconciliation. These services are delivered remotely through NHS clinical systems including EMIS and SystmOne, using NHSmail for secure communication.

The clinical workforce consists of qualified, General Pharmaceutical Council (GPhC) registered clinical pharmacists, all based in the United Kingdom, working remotely from home offices.

Clinical governance is led by Laura Elli Billyard, Clinical Director. Operational management including technology and compliance is overseen by Luke Adam Billyard, Operations Director.

The Company holds ICO Registration ZB127110, maintains a Data Security and Protection Toolkit (DSPT) ODS Code of S6I6X, and holds Cyber Essentials certification.

2. Our Business and Supply Chains

2.1 Our Business

Virtual Pharmacist Ltd provides clinical pharmacist services to NHS organisations across the United Kingdom. The core business is the provision of professional healthcare services delivered by qualified, GPhC-registered pharmacists. The Company does not manufacture goods, procure raw materials, or operate in industries traditionally associated with higher risks of modern slavery.

2.2 Our Supply Chain

As a professional services company, the supply chain is relatively straightforward and UK-based. Key supply chain categories include:

• Recruitment of clinical pharmacists: all pharmacists are verified through the GPhC register and must hold current registration to practise
• IT and technology providers: clinical systems access (EMIS, SystmOne), communication tools, and IT infrastructure
• Office supplies and equipment: equipment to support remote working, including computing hardware
• Professional services: legal, accounting, insurance, and other professional advisors
• Training and CPD providers: continuing professional development and training services for the clinical team

The Company does not operate in high-risk sectors or source goods or services from high-risk geographies. The primarily UK-based professional services and technology supply chain carries a lower inherent risk of modern slavery than supply chains involving manufacturing, agriculture, or international procurement.

3. Our Policies in Relation to Modern Slavery

Virtual Pharmacist Ltd maintains a range of policies and procedures relevant to identifying, preventing, and addressing modern slavery risks. These include:

• Recruitment and employment practices that ensure all personnel have the legal right to work in the United Kingdom and are fairly compensated for their work
• GPhC registration verification for all clinical personnel, conducted at recruitment and monitored on an ongoing basis
• Fair pay and transparent employment terms, with clear contracts and engagement terms for all team members
• Whistleblowing procedures enabling personnel to raise concerns confidentially and without fear of retaliation
• Safeguarding policies aligned with NHS requirements, including awareness of exploitation and trafficking indicators
• Supplier due diligence processes to assess modern slavery risks when engaging with new and existing suppliers
• Equality, diversity, and inclusion commitments that underpin a culture of fairness and respect throughout the organisation

4. Due Diligence and Risk Assessment

4.1 Risk Assessment

Virtual Pharmacist Ltd has conducted an assessment of the risk of modern slavery and human trafficking within its operations and supply chain. Given the nature of the business, being the provision of professional healthcare services delivered by qualified clinical pharmacists based in the United Kingdom, the overall risk is considered low. The Company does not take a complacent approach and remains vigilant and committed to identifying and addressing any potential risks.

4.2 Due Diligence Measures

Steps taken to identify and mitigate modern slavery risks include:

• Verifying the GPhC registration status of all pharmacists prior to engagement and on an ongoing basis
• Confirming the right to work in the United Kingdom for all personnel
• Ensuring fair and transparent pay practices that significantly exceed the National Living Wage
• Reviewing key suppliers’ modern slavery statements and policies where applicable
• Monitoring NHS guidance on modern slavery in healthcare supply chains
• Maintaining awareness of the indicators of modern slavery and human trafficking
• Ensuring all employment and engagement contracts are clear, fair, and freely entered into

5. Our Commitment to Our Workforce

All individuals who work with and for Virtual Pharmacist Ltd are treated fairly and with dignity. All clinical and operational personnel:

• Are employed or engaged on fair and transparent terms
• Receive remuneration that significantly exceeds the National Living Wage
• Have clear contracts outlining their terms of engagement, responsibilities, and rights
• Are free to terminate their employment or engagement in accordance with their contracts
• Work in a supportive remote working environment with appropriate management oversight
• Have access to appropriate training, continuing professional development, and career support
• Are encouraged to raise concerns through the whistleblowing procedures without fear of retaliation or detriment

Virtual Pharmacist Ltd does not use any form of forced, compulsory, or trafficked labour. The Company does not require workers to pay recruitment fees or to surrender identity documents as a condition of employment.

6. Training and Awareness

Virtual Pharmacist Ltd is committed to ensuring that its directors, management team, and wider workforce are aware of modern slavery risks and the indicators of exploitation and trafficking.

Clinical personnel complete safeguarding training which includes awareness of modern slavery and human trafficking. This training helps the team to recognise potential signs of exploitation in the course of clinical work and in wider professional interactions. The Company is committed to increasing awareness of modern slavery throughout the organisation and will continue to develop its training programme as best practice evolves.

7. Measuring Effectiveness

Virtual Pharmacist Ltd evaluates its performance in preventing modern slavery through the following measures:

• Monitoring any reports of concerns raised through the whistleblowing procedures
• Reviewing the supply chain annually for potential modern slavery risks
• Keeping up to date with NHS guidance and requirements on modern slavery in healthcare
• Engaging with NHS procurement processes that include modern slavery requirements
• Tracking completion of safeguarding and modern slavery awareness training

8. Looking Ahead

For the coming financial year, Virtual Pharmacist Ltd commits to the following actions:

• Continuing to review and strengthen policies and procedures in relation to modern slavery
• Maintaining alignment with NHS Standard Contract requirements, including Section 19 provisions
• Enhancing supplier due diligence processes as the supply chain develops
• Providing ongoing training and awareness to the team, including updated safeguarding content
• Publishing an updated Modern Slavery Statement annually
• Engaging with sector-wide initiatives to combat modern slavery in healthcare supply chains

9. Approval

This voluntary Modern Slavery and Human Trafficking Statement has been reviewed and approved by Luke Adam Billyard, Operations Director, on behalf of Virtual Pharmacist Ltd.

10. Contact Information

If you have any concerns regarding modern slavery or human trafficking in relation to the Company’s business or supply chain, or if you wish to discuss any aspect of this statement, please contact:

Virtual Pharmacist Ltd Queen Street Chambers, 68 Queen Street, Sheffield, South Yorkshire, S1 1WR Email: [email protected] Telephone: 0113 871 5065 Company Number: 13258094

All reports are taken seriously and any concerns raised will be investigated in confidence.