Modern slavery and human trafficking



This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, sets out Wellbeing Centres’ actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 2019/2020.

As part of the healthcare sector, Wellbeing Centres recognises that it has a responsibility to take a robust approach to slavery and human trafficking. Wellbeing Centres is absolutely committed to preventing slavery and human trafficking in its corporate activities, and ensuring that those in its supply chains, and contractors, are free from slavery and human trafficking and comply with our values.


Organisational structure and supply chains

Wellbeing Centres is a provider of rehabilitation services providing services to insurers, personal injury and private patients in London. Wellbeing Centres’ supply chain mainly comprises physiotherapy and treatment providers instructed to provide physiotherapy and related services.


Risk Assessment Process

On an annual basis, Wellbeing Centres evaluates the business risks, sector risks, transaction risks and business partnerships, to determine whether or not particular activities or countries are high risk in relation to slavery or human trafficking. Any risks identified from the above process will be prioritised and dealt with in accordance with the due diligence section below.


High-risk activities

Wellbeing Centres does not believe it has any particular activities or is involved with any countries which are high risk in relation to slavery or human trafficking.



Responsibility for Wellbeing Centres' anti-slavery initiatives is as follows:


  • Wellbeing Centres Leadership Team;
  • Policies - HR department;
  • Risk assessment, Due diligence and Training - Directors, Governance & Quality.


Relevant policies

Wellbeing Centres operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:


Whistleblowing policy: Wellbeing Centres encourages all its staff, clients and other business partners to report any concerns related to the direct activities, or the supply chains of, Wellbeing Centres. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Wellbeing Centres' whistleblowing procedure is designed to make it easy for staff to make disclosures, without fear of retaliation. Employees, clients or others who have concerns can complete our confidential disclosure form.


Employee code of conduct: Wellbeing Centres’ code makes clear to employees the actions and behaviour expected of them when representing Wellbeing Centres. Wellbeing Centres strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.


Environmental Management System: It is part of Wellbeing Centres’ on-going commitment to reduce the impact the company has on the environment by checking and monitoring suppliers and contractors standards through a third party questionnaire. This process of checking supplier standards can be expanded to include Human Trafficking and slavery checks to increase knowledge and confidence when dealing with suppliers and contractors.


Quality Management System: The Quality Policy sets out Wellbeing Centres’ commitment to high quality practices, including a collaborative partnership approach to working with our key suppliers. Our commitment to this approach allows us to have confidence in our suppliers’ commitment to preventing slavery and human trafficking in their operations, and those of their suppliers.


Sustainability and Environmental Management Policy: This policy builds upon our ISO14001 Environmental Management System to incorporate wider aspects of sustainability, beyond environmental aspects, and details Wellbeing Centres’ approach to sustainability. Wellbeing Centres recognises that sustainable practices are good for business, good for our commissioners and purchasers, and good for the localities and communities within which we operate. Sustainability must be an integral part of our operations, ensuring that we consider the wider impact of our business operations and decisions. This contributes to a sustainable future recognising that we need to meet the needs of the present without compromising the future.


Due diligence

Wellbeing Centres has committed to undertaking due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Wellbeing Centres' due diligence and reviews will include:


Broadly considering suppliers to assess particular product or geographical risks of modern slavery and human trafficking;


When engaging a new frequent supplier as part of contract negotiations/tender processes, enquire if they are a business that is required to have a Modern Slavery and Human Trafficking Statement, and what policies they have in place;


Evaluating the modern slavery and human trafficking risks of each new supplier;

Where we identify high risk areas, explore those suppliers in greater detail;

Taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans;

Where a potential frequent supplier is unwilling to provide statements, or complete a questionnaire on the matter, we will consider if we commence that business relationship;

Invoking sanctions against suppliers that fail to improve their performance in line with an action plan, including the termination of the business relationship.

Ensuring contractual controls are in place with suppliers in relation to complying with Modern Slavery legislation.


Performance indicators

In order to assess the effectiveness of our approach to modern slavery Wellbeing Centres will be reviewing on an annual basis the following areas:


Staff awareness;

Reviewing existing supply chains; and

Developing a new suppliers’ evaluation process.


Awareness-raising programme

Wellbeing Centres will raise awareness of modern slavery issues via our intranet, explaining:

The basic principles of the Modern Slavery Act 2015;

Online bookings