Introduction 

This statement is made pursuant to section 54(1) of the modern Slavery Act 2015 (the Act) and sets out the steps taken by Bespoke Healthcare in preventing modern slavery and human trafficking in its business and supply chains.

This statement covers the calendar year 2024. Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply 

chain.  

At Bespoke Healthcare, we have a zero-tolerance approach to modern slavery and are fully  committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2024.  

Our business and supply chains  

• Bespoke Healthcare (Holdings) Ltd: Bespoke Healthcare Ltd and Greater Lancashire 
• Hospital 
• Specialist medical practice activities/ surgical procedures and treatment of disease, disorder or injury 
• United Kingdom for various NHS contracts. Greater Lancashire hospital is based in Preston Lancashire 

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.  

We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities. 

Risk assessment 

We recognise that whilst we are a UK based orgasniation, modern slavery is a complex, global issue which affects the healthcare sector. Our principle areas of focus for our organisation are in safeguarding patients and anyone else who comes through our facility and in our supply chain 

In the past year, we conducted a risk assessment of our supply chain by taking into account:

  

• The risk profile of individual countries based on the Global Slavery Index  
• The business services rendered by the suppliers   

• The presence of vulnerable demographic groups  
• A news analysis and the insights of labour and human rights groups  

This assessment will determine our response and the risk controls that we implement.  

Bespoke Healthcare educate our staff to identify and deal with modern slavery issues through the training and protections in place to protect pateinnts. Our safeguarding systems train our practitioners and all other colleagues, clinical and non-clinical, to recognise and report signs of abuse. All staff are futher supported by training and our infrastructure in place. All colleagues are able to raise concerns, thorough our Freedom to Speak Up Guardian and FTSU champions.  

Policies  

Bespoke Healthcare (Holdings) Ltd operates the following policies for identifying and preventing slavery and human trafficking in our operations:  

• Whistleblowing Policy – we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide  confidential support to protect the identity of whistle-blowers and have Freedom to Speak Up Guardian and champions. 
• Code of Conduct – our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating  abroad and managing our supply chain.  
• Purchasing Contracts – we have updated our Purchasing  contracts to make explicit reference to slavery and human trafficking.  

Supplier due diligence  

Bespoke Healthcare conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:  

• Assessing risks in the provision of particular services  
• Auditing the suppliers, and their health and safety standards, labour relations and employee contracts  
• Requiring improvements to substandard employment practices  
• Sanctioning suppliers that fail to improve their performance in line with our requirements 

 

We require all suppliers to attest that:  

• They don’t use any form of forced, compulsory or slave labour  
• Their employees work voluntarily and are entitled to leave work  
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment  
• They don’t require employees to post a deposit/bond and don’t withhold their salaries for  any reasons  
• They don’t require employees to surrender their passports or work permits as a condition of employment  

Awareness

Bespoke Healthcare has raised awareness of modern slavery issues by the provision of regular training and updates for all our staff. Our specific policy includes:

• Our commitment in the fight against modern slavery

• Red flags for potential cases of slavery or human trafficking

• How employees should report suspicions of modern slavery

Training

In addition to the awareness programme, Bespoke Healthcare has included mandatory Modern Slavery e-learning modules to all employees which covers:

• Various forms of modern slavery in which people can be held and exploited

• The size of the problem and the risk to our organisation

• How employees can identify the signs of slavery and human trafficking, including

unrealistically low prices

• How employees should respond if they suspect slavery or human trafficking

• What external help is available for the victims of slavery

• What terms and guidance should be provided to suppliers in relation to our slavery policies and controls

This statement covers 4 January 2024 to 4 January 2025 and has been approved by the board of Bespoke Healthcare( Holdings) Ltd