Modern Slavery Statement

Financial Year Ending 31 December 2025

Introduction and Organisational Structure

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that Optegra UK Limited has taken during the financial year ending 31 December 2025 to prevent modern slavery and human trafficking in its business operations and supply chains.

Optegra UK Limited operates 19 hospitals across England, providing a range of ophthalmology services including refractive lens exchange, laser eye surgery, cataract, glaucoma and AMD treatments to both private and NHS patients.

Optegra UK Limited (company number 05846041) and its subsidiary, Custom Vision Clinic Limited (company number 06268954), are private limited companies registered in England and Wales.

Further information about our organisation can be found on our website.

Policies in Relation to Modern Slavery and Human Trafficking

Optegra is committed to acting ethically and with integrity in all business dealings and relationships and to implementing effective systems and controls to ensure modern slavery and human trafficking are not taking place anywhere in our business or supply chains.

We fully support the UK Government’s objectives to eradicate modern slavery and recognise the important role healthcare providers play in identifying and responding to risks.

Our commitment is supported by a number of internal policies, including:

  • Freedom to Speak Up (Whistleblowing) Policy
  • Equality, Diversity and Inclusion Policy
  • Safeguarding Policy

These policies are reviewed regularly and made available to employees.

Due Diligence Processes

As part of our supplier onboarding and procurement processes, we undertake proportionate and risk-based due diligence on relevant suppliers. This may include:

  • Reviewing modern slavery statements (where applicable)
  • Assessing policies and controls relating to labour standards
  • Reviewing Companies House filings and publicly available information
  • Considering adverse media or reputational risks

We continue to strengthen our processes to ensure appropriate scrutiny is applied, particularly for higher-risk suppliers.

Risk Assessment and Management

We recognise that modern slavery risks can arise both in the UK and internationally, particularly within:

  • Outsourced services (e.g. cleaning, facilities management)
  • Manufacturing and supply of medical equipment and consumables
  • Agency and temporary labour

We adopt a risk-based approach by categorising suppliers and applying enhanced due diligence where higher risks are identified.

Where concerns arise, we will:

  • Engage with the supplier to understand the issue
  • Agree appropriate remedial actions
  • Monitor progress against agreed actions

We maintain a zero-tolerance approach to modern slavery. Where a supplier is unwilling or unable to address concerns, we will consider termination of the relationship.

Effectiveness and Key Performance Indicators

To measure the effectiveness of our approach, we continue to develop and monitor appropriate key performance indicators (KPIs), which may include:

  • Completion of due diligence checks on new suppliers
  • Number of concerns raised and investigated
  • Training completion rates
  • Supplier engagement on modern slavery requirements

During 2025, we have continued to embed our processes and will further enhance our ability to track and report on effectiveness over time.

Training and Awareness

We provide appropriate training to ensure employees understand the risks of modern slavery and how to identify and report concerns. This includes:

  • Mandatory training for relevant staff
  • Safeguarding training within clinical environments
  • Guidance for managers

Employees are encouraged to raise concerns through their line manager, HR, or via our Freedom to Speak Up arrangements.

Review and Approval

This statement has been approved by the UK Leadership Team of Optegra UK Limited in May 2026 and signed on its behalf.

Signed:

Jennifer Abbott
Operations Director
Optegra UK Limited

Date: 1st June 2026