Modern Slavery statement for the financial year 1 April 2021 to 31 March 2022
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out our approach to understand all potential modern slavery risks related to our business, and to put in place steps aimed at ensuring that there is no slavery or human trafficking in either our own business or our supply chains. Modern slavery encompasses slavery, human trafficking and forced labour.
Our Business Structure
Westfield Contributory Health Scheme Limited (WCHS Ltd) is the parent company of Westfield Health & Wellbeing Limited (WH&W Ltd), Westfield Employment Services Limited (WES Ltd), Westfield Health Ltd and Bolton and District Hospital Saturday Council (t/a UK Healthcare) (BDHSC).
Our Business Activities
WCHS Ltd is a leading provider of Health Cash Plans and other health insurance products. WH&W Ltd is a provider of innovative health & wellbeing products and services. WES Ltd is the company that employs our staff for both WCHS Ltd and WH&W Ltd. BDHSC are providers of Health Cash Plans and other health insurance products.
We deal with a very small supplier base of under 100 key suppliers, almost all of which are UK based. Given the nature of our business we do not believe that we are greatly exposed to the risk of inadvertently becoming involved in modern slavery or human trafficking. However we have put in place measures to guard against this which we will continue to review and adapt as the business changes.
We have zero tolerance to slavery and human trafficking and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure, with best endeavours, that slavery and human trafficking is not taking place anywhere in our supply chains.
In 2018 we appointed a permanent Procurement professional to strengthen the control of our supply chain. Our Procurement Policy and Outsourcing Policy have been rewritten and are now annually reviewed documents.
In addition to our policies, we continue to implement and enforce our other policies relevant to Human Trafficking and Modern Slavery, including:
- our recruitment and employment policies; including a commitment to paying the national minimum and living wage rates as appropriate;
- whistleblowing policies;
- risk management and incident reporting policies;
- due diligence framework and requirements.
Due Diligence processes in relation to Slavery and Human Trafficking
We acknowledge our responsibility under the Modern Slavery Act 2015 and will ensure transparency both within our own organisation and with suppliers of goods and services.
We will not forge commercial relationships with any business knowingly involved with slavery, forced labour or human trafficking.
We will expect all who have, or seek a commercial relationship with ourselves, to familiarise themselves with The Modern Slavery Act and our anti-slavery aim and act consistently within these.
Effectiveness and Reporting
We monitor our performance through regular reviews of modern slavery related risk incident reporting and whistleblowing incidents. All incidents are reported to the Board. We regularly review our processes to ensure that they remain compliant with our legal obligations and that they remain fit for purpose as our business evolves and develops. During the financial year to 31 March 2022 there have been no reports of any slavery and/or human trafficking taking place within our business. This has been certified by:
- All new employees engaged throughout the year have been confirmed through our rigorous recruitment processes as having the right to remain and work in the UK;
- All employees meet the requirements of the National Minimum Wage;
- An audit has been conducted on supplier relationship management and contract management and an action plan developed to categorise our suppliers and ensure regular supplier management and due diligence is taking place in correlation with the importance of the supplier’s category;
- There having been no reports received from employees, the public or any law enforcement agency to indicate that any form of modern slavery practices have been identified.
Approved by: Board
Date: May 2022
David Capper – Chief Executive
Date: May 2022