Modern Slavery Policy Statement

Introduction

Live by Lulu Limited, trading as Caversham Health, is fully committed to combatting modern slavery and human trafficking within its business operations and supply chain. As a small but fast-growing company, we recognise our critical responsibility in ensuring ethical business practices, transparency, and continuous improvement in tackling modern slavery risks.

This statement is made in line with the UK Modern Slavery Act 2015 and the NHS procurement requirements, outlining our structure, policies, due diligence measures, risk assessment approach, performance indicators, and training commitments.

1. Organisation’s Structure, Business, and Supply Chains

Caversham Health is a UK-based company specialising in clinically compliant pressure and mobility care products. Our supply chain is small but international, consisting of:

Two key manufacturing partners based in China are responsible for producing our cushions and mattresses.
A global logistics partner, Forceget, manages the international transport of goods.
Warehousing and distribution operations based in the UK, primarily through Amazon Fulfilment Centres.

The Director of Operations is responsible for overseeing supply chain management and ensuring ethical compliance.

2. Policies in Relation to Slavery and Human Trafficking

Caversham Health has implemented a zero-tolerance policy towards modern slavery and human trafficking, ensuring that:

Supplier contracts include strict anti-slavery clauses and compliance requirements.
All new supplier agreements are contingent upon alignment with our ethical sourcing standards.
Our governance framework establishes clear accountability, with the Director of Operations overseeing policy enforcement.
An escalation procedure is in place to address any identified risks of non-compliance.

This policy will be reviewed annually to ensure it remains effective and responsive to evolving best practices.

3. Due Diligence Processes

We have developed and implemented robust due diligence processes to assess and address modern slavery risks in our supply chain. These include:

Supplier Pre-Qualification Assessments: All new suppliers undergo a modern slavery risk assessment before engagement.
Annual Supplier Audits:
- On-Site Audits: Conducted every three years for each key supplier, carried out by an independent third-party auditing firm.
- Desk-Based Reviews: Conducted annually for all suppliers, assessing compliance documentation and performance.
Supplier Self-Assessment Questionnaires (SAQs): Used to evaluate labour practices, working conditions, and wages.
Whistleblowing Mechanism: A confidential reporting channel is available for employees and supply chain workers to raise concerns.
Corrective Action Plans (CAPs): Any identified non-compliance issues will result in the supplier being required to implement a CAP within a specified timeframe.

4. Risk Assessment and Management

We recognise that sourcing from China presents an elevated risk of labour exploitation due to regional economic and regulatory factors. To address these risks:

We categorise suppliers based on risk exposure, with Chinese manufacturers classified as high-risk.
We prioritise partnerships with suppliers who demonstrate adherence to internationally recognised labour standards (e.g., ILO conventions, SA8000 certification).
Our supplier engagement includes direct dialogue, contractual obligations, and third-party verification where necessary.
Regular risk mapping exercises ensure we focus our mitigation efforts on the most vulnerable areas of our supply chain.
Escalation Procedure: If a supplier is found to be non-compliant, an internal investigation is launched, and immediate remediation steps are taken, which may include termination of the supplier relationship if corrective actions are not implemented.

5. Effectiveness and Performance Indicators

To measure our effectiveness in preventing modern slavery, we track the following key performance indicators (KPIs):

100% of supplier contracts will include modern slavery clauses by the end of 2025.
100% of suppliers will complete SAQs annually to assess ongoing compliance.
Completion of one on-site supplier audit per supplier every three years.
Investigation and resolution of all modern slavery concerns raised within six months.
Reduction of identified non-compliance issues year-on-year.
Annual reporting on progress towards our modern slavery commitments.
Publication of an annual Modern Slavery Report, detailing progress, key findings, and next steps.

6. Training and Capacity Building

We believe that education and awareness are key to preventing modern slavery. Our training programme includes:

Mandatory modern slavery training for all employees within their first six months, assessed through a post-training evaluation.
Specialised procurement training for supply chain managers to identify risks and ensure ethical sourcing.
Annual refresher courses for all relevant staff to ensure continued awareness.
Supplier Training Programme, aimed at supporting our partners in implementing best practices.
Effectiveness Monitoring: Training effectiveness is assessed via knowledge retention tests and feedback surveys.

Commitment to Continuous Improvement

Caversham Health is committed to the continual enhancement of our approach to tackling modern slavery. In the next three years, we aim to:

Strengthen data collection mechanisms to improve supply chain transparency.
Enhance supplier engagement through more frequent audits and collaborative improvements.
Develop an independent verification process for supplier-provided modern slavery data.
Increase stakeholder engagement, including external partnerships with NGOs and regulatory bodies.

This statement has been approved by the senior leadership team of Caversham Health and will be reviewed and updated annually to reflect our progress and ongoing commitments.

Ian Plunkett
Director
Live by Lulu Limited trading as Caversham Health
6 February 2025