Slavery and Human Trafficking Statement

Our Business Structure

Westfield Contributory Health Scheme Limited (WCHS Ltd) is the parent company of Westfield Health & Wellbeing Limited (WH & W Ltd) and Westfield Employee Services Limited (WES Ltd).

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 employees our staff.

Supply Chain

Given the nature of our business operations we do not believe that we are greatly exposed to the risk of inadvertently becoming involved in slavery and human trafficking. However in order to continue to guard against this, as our business evolves, we will routinely review our existing purchasing, due diligence and employment processes with regards to the requirements of the Modern Slavery Act 2015. This will determine associated risk, detection and prevention of modern day slavery and human trafficking within our supply chain for products and services to the organisation.

Relevant Policies

The Group has zero tolerance to slavery and human trafficking and is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its 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.

Relevant policies that we have in place to help us manage this include:

  • 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;
  • procurement procedures; and
  • due diligence framework and requirements.

Due Diligence processes in relation to Slavery and Human Trafficking

The Westfield Health Group acknowledges its responsibility under the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation.

We will not forge commercial relationships with any business knowingly involved with slavery 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 will monitor our performance through regular review of modern slavery related risk incident reporting and whistleblowing incidents. All incidents will be reported to the Board. We will regularly review our processes to ensure that they remain compliant with our legal obligations and that they remain fit-forpurpose as our business evolves and develops.

Approved by: Board

Date: May 2017

Signed By:
Jill Davies – Chief Executive

Jill Davies signature

Date: May 2017