1. Policy Statement
Livewell Corporate Ltd is committed to conducting business ethically, responsibly and with integrity. We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, bonded labour, child labour and all forms of exploitation.
We are committed to ensuring that modern slavery and human trafficking do not take place within our business operations, supply chains, subcontractor network or any part of the services we deliver.
As a provider of healthcare, wellbeing, clinical, corporate and event-based services across the United Kingdom, we recognise our responsibility to protect vulnerable individuals, uphold human rights and ensure ethical working practices at all times.
This policy reflects our commitment to acting in accordance with the Modern Slavery Act 2015, relevant employment legislation, safeguarding principles and broader human rights obligations.
2. Scope
This policy applies to:
- All employees
- Directors
- Contractors
- Self-employed practitioners
- Associate therapists
- Temporary workers
- Agency staff
- Volunteers
- Consultants
- Suppliers
- Service providers
- Business partners
- Third-party contractors
This policy applies across all areas of Livewell Corporate Ltd, including:
- Clinic operations
- Mobile healthcare services
- Corporate wellbeing services
- Event recovery services
- Training and education services
- Administrative operations
- Procurement and supplier engagement
3. Definition of Modern Slavery
Modern slavery is a broad term covering serious exploitation, including:
Human Trafficking
The recruitment, movement, transfer, harbouring or receipt of people through force, coercion, deception or abuse for exploitation.
Forced Labour
Work or services extracted from someone under threat, coercion or without genuine consent.
Bonded Labour / Debt Bondage
A person being forced to work to repay a debt or obligation.
Child Labour
The exploitation of children through work that is harmful, unsafe or interferes with education and development.
Domestic Servitude
Individuals forced to work in private households under exploitative conditions.
Labour Exploitation
Including withholding wages, confiscating identity documents, threatening immigration consequences, coercion, intimidation or restricting freedom of movement.
4. Our Commitment
Livewell Corporate Ltd will:
- Operate with honesty, transparency and ethical business conduct
- Comply with all relevant employment and safeguarding legislation
- Only engage workers voluntarily and lawfully
- Pay workers fairly and in accordance with legal requirements
- Never knowingly use forced, trafficked or exploitative labour
- Carry out proportionate due diligence when engaging suppliers and contractors
- Act promptly where concerns are raised
- Promote awareness of exploitation risks within the business
- Protect individuals who raise concerns in good faith
5. Risk Areas
We recognise that certain sectors and working models may carry increased risk, including:
- Use of subcontracted practitioners
- Temporary staffing arrangements
- Agency recruitment
- Outsourced service providers
- Procurement of uniforms, equipment or goods
- Cleaning or facilities contractors
- Overseas manufactured products or equipment
- Event staffing supply chains
Although Livewell Corporate Ltd operates primarily within the UK healthcare and wellbeing sector, risks may still arise indirectly through suppliers or third-party providers.
6. Recruitment & Employment Controls
To reduce the risk of exploitation, Livewell Corporate Ltd will:
- Verify identity and right to work where legally required
- Carry out appropriate recruitment checks
- Ensure clear contractual terms are provided
- Avoid unlawful deductions or exploitative payment arrangements
- Ensure workers are free to leave in accordance with contractual terms
- Not retain passports, ID documents or personal belongings
- Encourage direct communication with management
- Maintain fair pay practices
Where subcontracted practitioners operate under independent contractor arrangements, we expect full compliance with applicable law and ethical labour standards.
7. Supplier & Contractor Expectations
Livewell Corporate Ltd expects all suppliers, subcontractors and third parties to:
- Comply with the Modern Slavery Act 2015
- Maintain lawful employment practices
- Ensure workers are engaged voluntarily
- Pay workers fairly
- Prohibit forced labour, child labour and trafficking
- Implement appropriate controls within their own supply chains
- Cooperate with reasonable due diligence requests
- Notify us immediately if concerns arise
We reserve the right to review supplier relationships where concerns are identified.
8. Identifying Warning Signs
Potential indicators may include:
- Workers appearing fearful, anxious or controlled
- Individuals unable to speak freely
- Someone speaking on behalf of another person
- Signs of physical abuse, neglect or poor living conditions
- Lack of access to identification documents
- Workers being transported in groups under supervision
- Inconsistent pay arrangements
- Excessive working hours
- Evidence of coercion, threats or restricted movement
These signs do not automatically confirm exploitation but should prompt further review.
9. Reporting Concerns
Any employee, practitioner, contractor or stakeholder who suspects slavery, trafficking or exploitation must report concerns immediately.
Concerns may be reported to:
Managing Director
Livewell Corporate Ltd
Email: info@livewellhealth.co.uk
Telephone: 0330 043 2501
Where appropriate, concerns may also be escalated to:
- Police
- Local safeguarding authorities
- The Modern Slavery Helpline
- Relevant regulatory or enforcement bodies
Emergency situations should always be reported to 999.
10. Protection for Whistleblowers
Livewell Corporate Ltd will not tolerate retaliation against anyone who raises a genuine concern in good faith.
Any individual reporting concerns honestly will be treated fairly, respectfully and confidentially where possible.
Malicious or knowingly false allegations may be dealt with under disciplinary procedures.
11. Training & Awareness
Livewell Corporate Ltd will seek to ensure that relevant personnel understand:
- What modern slavery is
- How to identify warning signs
- Reporting procedures
- Supplier expectations
- Ethical recruitment standards
Training may be delivered through induction, policy circulation, management briefings or compliance updates.
12. Breach of Policy
Any employee, contractor or supplier found to be involved in slavery, trafficking or serious exploitation may face:
- Disciplinary action
- Immediate suspension
- Contract termination
- Supplier delisting
- Referral to law enforcement or regulators
13. Governance & Review
This policy will be reviewed periodically to ensure ongoing compliance and effectiveness.
Responsibility for implementation sits with senior management.
Approval
Approved by: Steven Hartill
Position: Managing Director