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Anti-Slavery & Human Trafficking Policy

Anti-Slavery and Human Trafficking Policy

Incorporating our voluntary Modern Slavery Statement

CoreCare Global Ltd, trading as Vivid Care  |  Version 2.0  |  July 2026

  1. Introduction and Scope

1.1  CoreCare Global Ltd, trading as Vivid Care, is a private limited company registered in England and Wales (company number 08931470), based at Rofta House, Rudgate, Wetherby, LS23 7AU. We design, supply, hire, service and support specialist care seating, beds, mobility equipment and moving and handling equipment for the NHS, care providers, case managers and private customers. All our employees are based in the UK.

1.2  Our annual turnover is below the £36 million threshold at which Section 54 of the Modern Slavery Act 2015 requires a slavery and human trafficking statement. We publish this document voluntarily because we believe every business in healthcare supply chains shares responsibility for preventing exploitation. This single document serves as both our anti-slavery policy and our voluntary modern slavery statement, and describes the steps we take to ensure modern slavery is not taking place in our business or supply chains.

1.3  This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, contractors, consultants and business partners. It does not form part of any employee’s contract of employment and we may amend it at any time.

  1. Our Organisation and Supply Chains

2.1  Our supply chain consists of:

  • Manufacturers of specialist seating, beds and healthcare equipment, and of the materials and components used in our own manufactured products, including timber, foam, fabrics, metalwork and electronic actuation systems.
  • Facilities and maintenance contractors.
  • Professional and support service providers, including logistics, IT and recruitment services.

2.2  Our tier 1 suppliers are based principally in the UK, Europe and Australia. We recognise that our supply chain extends beyond tier 1. In particular, electronic components such as actuators, control units and handsets used across our industry are typically manufactured by global drive technology groups with production facilities in Europe and Asia, including China. We treat this part of our supply chain as carrying a higher risk of modern slavery and prioritise it in our due diligence.

2.3  We have mapped our tier 1 suppliers and are working to improve visibility of tiers 2 and beyond, focusing first on electronic components and upholstery materials.

  1. Policy Statement

3.1  Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which involve the deprivation of a person’s liberty by another for personal or commercial gain. We have a zero tolerance approach to modern slavery in all its forms.

3.2  We are committed to acting ethically and with integrity in all our business dealings and to implementing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chains. We expect the same high standards from all our contractors, suppliers and business partners, and we expect our suppliers to hold their own suppliers to the same standards.

  1. Worker Protection Standards

4.1  We uphold, and require our suppliers to uphold, the following standards for all workers in our business and supply chains:

  • Adherence to all applicable local and national laws.
  • Freedom of workers to terminate their employment.
  • Freedom of movement.
  • Freedom of association and, where permitted by local law, the right to collective bargaining.
  • No threats of violence, harassment or intimidation.
  • No worker-paid recruitment fees.
  • No compulsory overtime.
  • No child labour.
  • No discrimination.
  • No confiscation or retention of workers’ original identification documents.
  • Access to remedy, compensation and justice for victims of modern slavery.

4.2  These standards are communicated to all suppliers at the outset of our business relationship. Compliance with this policy is included as a condition in our supplier contracts through specific anti-slavery clauses prohibiting the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.

  1. Risk Assessment

5.1  We recognise that different parts of our business and supply chains carry different levels of modern slavery risk. We assess risk by product category, sourcing geography, type of work and worker vulnerability. We have identified our highest risk areas as:

  • Electronic components and actuation systems, where manufacturing extends to Asia, including China.
  • Raw materials used in furniture manufacture, including timber, textiles and foam.
  • Manufacturing generally, which the International Labour Organization identifies as one of the sectors at highest risk of forced labour.
  • Temporary, seasonal and low skilled work within extended supply chains, and migrant workers, who can be disproportionately vulnerable to exploitation.

5.2  We review this risk assessment annually and whenever we take on a significant new supplier or product category.

  1. Due Diligence

6.1  To manage and prevent modern slavery risks, we:

  • Include specific anti-slavery clauses in our supplier contracts, as described in section 4.2.
  • Evaluate new suppliers before entering into commercial relationships, with only senior members of staff who have undergone modern slavery risk training authorised to sign contracts in areas of identified risk.
  • Engage with our suppliers on transparency and compliance with our anti-slavery standards, offering support and guidance to address any potential issues.
  • Reserve the right to conduct spot checks of the businesses that supply us in order to investigate any complaints or concerns.
  • Consider modern slavery risks at each stage of our procurement process, from needs identification and supplier selection through to contract award and in-life contract management.

6.2  Purchasing practices. We recognise that a buyer’s own behaviour can create pressures on suppliers that increase the risk of labour exploitation, such as aggressive pricing, unrealistic lead times and late payment. We are committed to responsible purchasing practices, including realistic lead times, fair payment terms and pricing that allows for sustainable production costs.

6.3  Responsible recruitment. Our own recruitment is conducted directly in the UK with right to work checks for all employees. Where we or our suppliers use recruitment agencies or labour providers, we expect them to comply with the standards in section 4, including the prohibition on worker-paid recruitment fees, which are a common driver of debt bondage.

  1. Reporting Concerns

7.1  The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of everyone working for us or on our behalf. You must notify your manager or the Compliance Manager as soon as possible if you believe or suspect that a breach of this policy has occurred or may occur, in any tier of our supply chain. If you are unsure whether a particular act or the treatment of workers constitutes modern slavery, raise it.

7.2  Concerns can be raised openly or in confidence, and workers in our supply chains can raise concerns with us directly through the contact details on our website.

7.3  We encourage openness and will support anyone who raises a genuine concern in good faith, even if they turn out to be mistaken. No one will suffer any detrimental treatment, such as dismissal, disciplinary action or threats, as a result of reporting a concern in good faith. If you believe you have suffered such treatment, inform the Compliance Manager immediately. Employees may also raise the matter formally through our Grievance Procedure, set out in the Employee Handbook.

  1. Responding to Incidents and Remediation

8.1  We take a victim-centred approach to any report or suspicion of modern slavery. The welfare and safety of affected workers is our first priority. The Compliance Manager will acknowledge any report within five working days and begin an investigation.

8.2  Where an issue is identified with a supplier, our default response is remediation rather than automatic termination. Where a supplier has been transparent, is cooperating with the relevant authorities, is actively implementing corrective actions and is not found to be complicit, we will work with them to address the root causes, and will require an action plan setting out the gaps identified, the root causes and the corrective action being taken. We reserve the right to terminate our relationship with any individual or organisation that is complicit in modern slavery, refuses to remediate or breaches this policy.

8.3  Where appropriate we will report suspected modern slavery to the relevant authorities, including the police and the Gangmasters and Labour Abuse Authority.

8.4  No incidences of modern slavery have been identified within our organisation or supply chains.

  1. Training and Awareness

9.1  Training on this policy and on the modern slavery risks facing our business forms part of the induction process for everyone who works for us, with refresher training provided when this policy is materially updated. Training covers the indicators of forced labour identified by the International Labour Organization, including restriction of movement, retention of identity documents, withholding of wages, debt bondage, intimidation and excessive overtime, and how to report suspicions.

9.2  Our zero tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

  1. Measuring Performance

10.1  We use the following key performance indicators to measure the effectiveness of our approach, reviewed annually by senior management:

  • Percentage of suppliers with anti-slavery contract clauses in place.
  • Completion of our annual supply chain risk assessment.
  • Number of supplier evaluations, spot checks and related due diligence activities completed each year.
  • Completion of modern slavery training by all staff, including at induction.
  • Number of concerns raised and time taken to respond.
  1. Governance and Responsibility

11.1  The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those under our control comply with it. This policy and statement have been approved by the board of directors.

11.2  The Compliance Manager has day to day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with queries and auditing internal controls. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and receive adequate and regular training.

11.3  Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

11.4  Comments, suggestions and queries on this policy are encouraged and should be addressed to the Compliance Manager.

  1. Our Plans for the Next 12 Months

12.1  We are committed to continuous improvement. Over the next 12 months we will:

  • Complete mapping of our tier 1 suppliers and improve visibility of tier 2 for our highest risk categories, starting with electronic components.
  • Confirm that anti-slavery clauses are in place across all active supplier contracts.
  • Refresh modern slavery training for all staff, covering the ILO indicators of forced labour.
  • Review the effectiveness of our reporting channels for workers in our business and supply chains.

Approval

This policy and voluntary statement was approved by the board of directors of CoreCare Global Ltd. It is reviewed annually and any updates are communicated to all stakeholders.

Name:  Tristan Hulbert

Position:  Managing Director, CoreCare Global Ltd

Date:  21/1/26

Next review:  21/1/27

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