Slavery and Human Trafficking Statement

Modern Slavery Statement for Westfield Contributory Health Scheme Ltd July 2024

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the approach of Westfield Contributory Health Scheme Ltd, and its relevant Group subsidiaries, 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

Westfield Contributory Health Scheme Ltd (WCHS) is a leading provider of Health Cash Plans and other health insurance products. Westfield Health & Wellbeing Ltd (WH&W) is a provider of innovative health & wellbeing products and services. Westfield Employment Services Ltd is the company that employs our staff for both WCHS Ltd and WH&W Ltd. Bolton District Hospital Saturday Council (BDHSC) are providers of Health Cash Plans and other health & wellbeing products and services. High Five Health Promotion B.V (HFHP) provides corporate gyms and wellbeing programmes for companies.

Supplier Base

Our supplier base is considered to be relatively small. 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. We acknowledge however that Modern Slavery can exist anywhere and therefore we have put in place measures to guard against this which we will continue to review and adapt as the business changes.

Our commitment

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.

We have a Procurement and Outsourcing Policy which places emphasis on the ongoing management of our supplier base and contracting process. WCHS now endeavour to use our standard terms and conditions with suppliers, which includes contractual obligations on the supplier relating to;

• Anti-corruption & Anti-bribery
• Respect for Human Rights and Fair Labour Practices (including Modern Slavery)
• Living Wage
• Whistleblowing

All key suppliers must attend regular supplier review meetings and perform regular Due Diligence checks.

In addition to the above WCHS Ltd continues to implement and enforce other polices 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
• 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 this reporting year 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
• Policies in place to ensure supplier relationship management and contract management
• 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