Modern Slavery (Anti-Slavery and Human Trafficking) Policy

Policy status and annual modern slavery statement

This document is Baywater Healthcare’s Modern Slavery (Anti-Slavery and Human Trafficking) Policy. It sets out the company’s ongoing requirements, responsibilities and expectations for preventing modern slavery and human trafficking within its business and supply chains.

Baywater Healthcare has an annual turnover above £36 million and publishes an annual Modern Slavery and Human Trafficking Statement on its website in accordance with Section 54 of the Modern Slavery Act 2015. The annual statement is approved and published separately and is supported by this policy.

Company structure and operations

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

Scope

This policy applies to all persons working for Baywater Healthcare or on behalf of the company, in any capacity, and all suppliers providing services across its supply chain or in any part of the business.

This includes employees at all levels; directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This also includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, are included in all contracting processes with suppliers. Suppliers are expected to hold their own suppliers accountable and responsible to the same high safeguarding standards.

Related company policies and procedures

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

• Equality and Diversity Policy
• Attitudes and Behaviours Policy
• Safeguarding Adults
• Safeguarding Children and Young People Policy
• Procurement Policy
• Procurement Strategy
• Whistleblowing policy
• Labour Standards and Ethical Employment Policy

Responsibilities

Ultimate accountability for modern slavery compliance rests with the Executive Leadership Team and Board of Directors.

The Procurement Manager has overall responsibility for ensuring this policy is adhered to and for monitoring its use and effectiveness.

The Procurement Manager is responsible for addressing queries relating to this policy, and for auditing internal control systems and procedures to ensure that all controls remain effective, legally compliant and current.

The Procurement Department has responsibility for ensuring compliance with this policy for the company’s supply chain; in all contracts and business agreements and all standards in suppliers’ business partners and/or suppliers.
Senior Management have endorsed this policy and committed to review it regularly.

Business area managers have day to day responsibility to ensure compliance with all legal and ethical obligations.

All managers will ensure that reporting staff members understand and comply with this policy, and undertake any mandatory internal training provided by the company.

All employees have an individual responsibility for the successful prevention of slavery and human trafficking and are expected to comply with all laws.

Baywater Healthcare undertakes appropriate employment checks to verify identity, right to work and employment status and does not tolerate the charging of recruitment fees that could contribute to debt bondage or exploitation.

Compliance with this policy

The prevention, detection and reporting of modern slavery in any part of Baywater Healthcare’s business or supply chain is the responsibility of all employees or anyone engaged in activities under the company’s control.

All employees are required to avoid any activity that might lead to, or suggest a breach of this policy.

All employees must read, understand and comply with this policy.

Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the business or supply chains of any supplier tier at the earliest possible stage.

The Procurement Manager or appropriate Line Manager must be notified immediately if there is any suspicion of a conflict with the policy or any indication that a conflict may occur in the future.

If preferred, then any potential or possible conflict with this policy can be reported in accordance with the company’s Whistleblowing Policy.

Baywater Healthcare encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

Baywater Healthcare is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of their business or in any of the supply chains.

Any concerns about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the supply chains constitutes any of the various forms of modern slavery, it must be raised with the Procurement Manager or appropriate Line Manager.

Where appropriate, Baywater Healthcare will cooperate fully with law enforcement agencies, safeguarding authorities and regulatory bodies.

Suppliers to the company are regularly audited in order to continue to influence and have assurance of compliance with this policy.

Communication and awareness of this policy

All employees will be provided with training for awareness and understanding of this policy and this training module will be made available to all new employees as part of the mandatory induction package.

Baywater Healthcare’s approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of any business relationship with them and reinforced as appropriate thereafter.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Baywater Healthcare may terminate their relationship with other individuals and organisations working on our behalf or providing services if they breach this policy.

Risk assessment

We regularly assess the risk of modern slavery within our operations and supply chains. This assessment includes evaluating the countries and industries in which we operate, as well as conducting risk assessments of our suppliers. We use this information to prioritise areas for action and implement appropriate measures to mitigate risks.

Due dilligence

Baywater Healthcare has established due diligence processes to ensure that our suppliers and stakeholders share our commitment to eliminating modern slavery. We will conduct due diligence on our suppliers to assess their compliance with anti-slavery and human trafficking laws. This includes evaluating their policies, practices, and procedures related to modern slavery and human trafficking. We have a Supplier Code of Conduct in place outlining our expectations of suppliers to support our commitment to eliminating modern slavery. Our Procurement team are responsible for conducting supplier assessments to evaluate their policies and practices related to human rights and labour standards. We engage with suppliers to provide guidance and support in implementing best practices for ethical sourcing and labour standards.

Monitoring

Baywater Healthcare monitors its efforts to combat modern slavery through regular audits, reviews and assessments. We have an internal audit schedule covering all operations and supply chains to ensure compliance with our policies and identify areas for improvement. We adopt a continuous improvement approach and enlist the support of external stakeholders and industry partners to gather feedback to improve our approach.

Baywater Healthcare use the following monitoring indicators to measure the effectiveness of actions in managing the modern slavery and human trafficking risks in any part of its business or supply chains:

• All suppliers confirming their adherence to the Modern Slavery Act 2015 by signing the Supplier Code of Conduct
• Regular monitoring of modern slavery risks with our suppliers which informs gap analysis and reflective action log and programme
• All Corporate procurement and Contracts teams complete CIPS ethical procurement training
• All employees acknowledging receipt of the Modern Slavery and Human Trafficking Policy
• The number of cases reported, how it results in action and the lessons learned moving forward

This policy is endorsed by:

Adam Sullivan
Chief Executive Officer
Date of signature: 01/07/2026

Ian Williams
Finance Director
Date of signature: 01/07/2026