Modern Slavery and Human Trafficking Statement

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Baywater Healthcare recognises that it has a legal and ethical responsibility to take a robust approach to modern slavery and human trafficking. We are committed to acting ethically, with integrity and transparency in all business dealings, and to taking appropriate, proportionate and risk-based steps to prevent modern slavery and human trafficking within our business and supply chains.

Our approach is consistent with the disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from our contractors, suppliers and business partners and continue to implement systems and controls designed to reduce the risk of modern slavery occurring within our operations or supply chains.

Organisation structure and supply chains

Baywater Healthcare is a specialist homecare service provider that delivers services on behalf of the NHS. Our registered company is in England, with our Head Office based in Crewe, Cheshire. We operate in the Home Oxygen and Respiratory Therapy markets across the United Kingdom.

Our supply chain supports the delivery of healthcare services and includes suppliers, contractors and service providers who support our operational, clinical, logistical, procurement, facilities and business support activities.

Policies in relation to slavery and human trafficking

Baywater Healthcare recognises its responsibility to combat modern slavery and human trafficking within its supply chain and operations. As a supplier delivering services on behalf of the NHS, we are committed to upholding high standards of ethical conduct and ensuring that slavery and human trafficking have no place in any aspect of our business activities.

This policy is communicated to employees and suppliers, emphasising our zero-tolerance approach to modern slavery and human trafficking. The Modern Slavery and Human Trafficking Policy interacts with relevant workplace policies and procedures, which can be found in the company’s Quality Management System. Employees are encouraged to review these policies regularly, and they are also available on request from Baywater Healthcare’s HR department.

Due diligence processes

During the reporting year, Baywater Healthcare continued to apply due diligence controls to help ensure that suppliers and relevant stakeholders share our commitment to preventing modern slavery and human trafficking.

This included the continued use of supplier assessment processes, procurement review controls and the Supplier Code of Conduct, which outlines our expectations of suppliers in relation to ethical conduct, labour standards and human rights. Where appropriate, suppliers were assessed against relevant expectations relating to modern slavery, human trafficking, ethical sourcing and labour standards.

Our Procurement team continued to have responsibility for supplier assessment activity and for engaging with suppliers where further information, guidance or improvement was required. We also continued to expect suppliers to conduct their activities in a way that is consistent with applicable anti-slavery and human trafficking legislation and our own standards of ethical business conduct.

Risk assessment and management

Baywater Healthcare continues to assess the risk of modern slavery within its operations and supply chains. This includes considering the types of goods and services procured, the nature of supplier activities, the countries and sectors in which suppliers operate, and the extent to which labour or subcontracted services may be involved in the delivery of goods or services.

We use this information to help prioritise areas for review and to apply proportionate measures to manage identified risks. Where concerns or higher-risk areas are identified, appropriate action may include further supplier engagement, additional information requests, review of supplier controls, or escalation through the relevant management and procurement channels.

Monitoring

Baywater Healthcare monitors its efforts to combat modern slavery through reviews, assessments and supplier engagement activity. We continue to adopt a continuous improvement approach and seek to strengthen our understanding of supply chain risks over time.

Monitoring activities are used to support compliance with our policies, identify opportunities for improvement and help ensure that appropriate controls remain in place. Baywater Healthcare remains committed to improving its approach to managing the risk of modern slavery and human trafficking in its business and supply chains.

Training on modern slavery and human trafficking

Baywater Healthcare provides training and awareness activity to support employees in understanding modern slavery and human trafficking risks. This training is intended to help employees recognise potential signs of exploitation, understand relevant legal and ethical expectations, and know how to escalate concerns.

During the reporting year, modern slavery training was provided to HR, Learning and Development, and senior managers. This helped strengthen awareness among key groups involved in people management, employee development, operational leadership and organisational decision-making.

The training covered matters including the different forms of modern slavery, such as forced labour, human trafficking and exploitative practices; the importance of identifying potential warning signs; and the reporting routes available for raising concerns. Employees are encouraged to report any concerns at the earliest opportunity through appropriate internal channels, including line management, HR or the company’s whistleblowing arrangements.

Approval

This statement has been approved by the Board of Directors of Baywater Healthcare UK Limited.

Signed on behalf of Baywater Healthcare UK Limited.

Name: Adam Sullivan
Position: Chief Executive Officer
Date: 01 July 2026