NHS buying from China: modern slavery checks
An NHS buyer should confirm the procurement scope, assess modern slavery risk, obtain proportionate supplier evidence and check exclusion grounds before award. Put reporting, verification and corrective action into the contract. Cambridge China Bridge can gather factory evidence through its own staff in China.
Confirm the scope before choosing the supplier
PPN 009 includes NHS bodies awarding public contracts for goods, services or works, except special regime contracts. In-scope organisations must use its guidance for new procurement activity and existing contracts. Buying through a UK intermediary does not replace the buyer’s risk assessment.
For health-service purchasing in England, also check the NHS procurement slavery and human trafficking regulations. They require an initial risk assessment, subject to framework and dynamic-market exceptions, and require public bodies to have regard to NHS England guidance. Ask your procurement team to confirm the applicable route before issuing the enquiry.
Assess the purchase, not just the supplier’s address
Use the guidance’s risk characteristics to record a low, medium or high assessment: industry, workforce, supplier location, operating context, commodity and supply-chain model. Combine the characteristics rather than treating a Chinese address as the whole assessment. Explain which evidence supports the rating and what remains unknown.
Ask about production sites, material sources, recruitment agencies and subcontracted processes. Match the questions to the goods being purchased. For the wider continuity questions, use our China supply resilience guide. Keep resilience planning and worker-risk evidence distinct in the procurement file.
Turn the risk rating into evidence requests
PPN 009 calls for supply-chain information in new procurements assessed as high risk. Exclusion grounds should be considered at the start and checked again just before award. Use the subcontractor exclusion guide for that separate check rather than treating an audit certificate as an exclusion decision.
For a factory evidence pack, request site identities, the scope and date of existing audits, recruitment arrangements and records of unresolved findings. Ask how workers can raise concerns confidentially. Identify which records relate to the actual production site and which merely describe the bidder’s general policy.
Write controls that match the identified risks
The guidance requires a proportionate approach without unnecessary burdens on smaller suppliers. It provides example contract clauses and says buyers must obtain their own legal advice before adding stronger protections for high-risk contracts. Avoid requesting the same extensive audit package for every purchase.
Consider reporting duties, access to supporting records, corrective-action plans and inspection rights, including direct worker interviews where appropriate. State who arranges checks, who pays and how findings are escalated. For goods production, agree notification and approval of factory or subcontractor changes using our factory subcontracting guide.
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Make the award file usable during delivery
Before award, assemble the risk assessment, supplier responses, exclusion-check record, unresolved questions and agreed controls. Name the contract manager and identify the evidence needed to close each open issue. Treat this as the handover pack for managing the order, rather than paperwork that stops at supplier selection.
An audit does not guarantee that hidden exploitation will be detected. Agree review points, reporting contacts and a response process that considers worker safety as well as supply continuity. Our guide to ethical audit limitations explains why a satisfactory report still needs follow-up.
Frequently asked questions
Does PPN 009 apply to NHS buyers?
Yes. It explicitly includes NHS bodies awarding public contracts for goods, services or works, other than special regime contracts. Confirm the procurement route with your commercial team.
Is buying from China automatically high risk?
Assess the combination of industry, workforce, location, operating context, commodity and supply-chain model. Record the reasons for the rating rather than relying on the country name alone.
Is a factory audit enough before an NHS purchase?
An audit cannot guarantee that hidden exploitation will surface. Check its scope, unresolved findings and relevance to the production site, then agree how evidence and concerns will be followed up.
What modern slavery controls should the contract include?
Consider evidence reporting, record access, corrective-action plans and inspection rights. Match them to assessed risk, define responsibilities and costs, and obtain legal advice for stronger high-risk protections.