Modern Slavery Statement | Tinywell Healthcare

MODERN SLAVERY

STATEMENT & POLICY

Our commitment to ethical employment and a slavery-free supply chain

Prepared with regard to section 54 of the Modern Slavery Act 2015 and the Home Office Transparency in Supply Chains

statutory guidance

1. Introduction and statement of commitment

Tinywell Healthcare Services Limited (“Tinywell”, “the Company”) is committed to acting ethically and with integrity in all its business relationships, and to preventing modern slavery and human trafficking in its own operations and its supply chain. Modern slavery is a crime and a grave violation of fundamental human rights. It takes many forms — including slavery, servitude, forced and compulsory labour, debt bondage and human trafficking — all of which deprive a person of their liberty in order to exploit them for personal or commercial gain. Tinywell has a zero-tolerance approach to modern slavery in every part of its business.

As a provider of adult social care, supported living and healthcare staffing, we work every day with people who may be vulnerable, and we employ and place a large workforce of care professionals. We understand that the care sector carries particular modern-slavery risks — including labour exploitation of care workers, recruitment malpractice and the abuse of vulnerable adults — and we take our responsibility to identify, prevent and respond to those risks seriously.

Our commitment

Tinywell Healthcare Services Limited will not tolerate slavery, servitude, forced or compulsory labour or human trafficking in any part of its business or supply chain. We are committed to treating everyone who works for and with us fairly, lawfully and with dignity, and to acting promptly and decisively wherever a concern is raised. This commitment is owned by our Board of Directors and applies to every director, employee, worker and contractor.

1.1 Purpose and status of this document

This document serves two connected purposes. It is both Tinywell’s modern slavery and human trafficking statement and the internal policy that governs how we meet that commitment in practice. It has been prepared having regard to section 54 of the Modern Slavery Act 2015 and the Home Office Transparency in Supply Chains statutory guidance (updated March 2025), and is structured around the six areas of disclosure recommended in that guidance.

A note on our legal position

The statutory duty in section 54 of the Modern Slavery Act 2015 applies to commercial organisations with a total annual turnover of £36 million or more. Tinywell’s turnover is below this threshold, so we are not legally required to publish a statement. We nevertheless choose to publish this statement and policy voluntarily — because preventing modern slavery is the right thing to do, because our commissioners and partners rightly expect it, and because transparency strengthens trust in our services.

2. Our organisation, business and supply chains

Structure. Tinywell Healthcare Services Limited is a private limited company (no. 06579735) incorporated in England & Wales, with its registered office in Slough. It is an independent company with no subsidiaries or parent undertaking, governed by its Board of Directors and senior management team.

Our business. We deliver regulated adult social care (domiciliary and live-in care, dementia and mental health support, complex care), supported living and supported accommodation, and a healthcare recruitment and staffing service that supplies trained, vetted care professionals to hospitals, care homes, supported-living services, education and community providers across Berkshire and the surrounding areas.

Our workforce. Our people are central to our business. We employ and engage a workforce of care and support professionals, including a deployable pool of more than 150 care workers, alongside a core management and office team. Because we recruit and place workers at scale, safe and ethical recruitment is the single most important control in our approach to modern slavery.

2.1 Our supply chain

Tinywell delivers regulated care through its own employed and bank workforce rather than subcontracting care delivery. Our supply chain is therefore relatively short and consists mainly of business-support suppliers, including:

Recruitment sources and channels through which we attract care workers (including direct applicants, job boards and, where used, recruitment partners);
Accredited training providers delivering mandatory and specialist training;
Our electronic care-management and call-monitoring software provider;
Suppliers of PPE, uniforms, consumables and office supplies;
Professional services such as our DBS umbrella body, occupational-health provider, insurance broker, payroll/factoring and IT services.

We recognise that the highest inherent modern-slavery risk in our model lies in the recruitment and employment of workers — particularly any worker recruited through third parties or from overseas — and in lower-tier suppliers of manufactured goods such as PPE.

3. Our policies in relation to modern slavery

Our approach to modern slavery is supported by a framework of internal policies that together set the standards of behaviour we expect and the safeguards we apply. These include:

This Modern Slavery Statement & Policy — setting out our zero-tolerance commitment and how we deliver it.
Recruitment and Retention Policy — governing safe, fair and lawful recruitment, including right-to work and identity checks.
Safeguarding (Adults & Children) Policy — under which any indication of exploitation is treated as a safeguarding concern.
Whistleblowing and Complaints Handling Policy — providing a protected route for anyone to raise concerns.
Equality and Diversity Policy — ensuring fair and non-discriminatory treatment of all workers.
Health and Safety, and Lone Working policies — protecting the welfare of staff in the workplace and in the community.

These policies are communicated to staff, reviewed regularly, and applied consistently across the organisation.

4. Assessing and managing risk

We assess modern-slavery risk across both our workforce and our supply chain, focusing our effort on the areas of greatest inherent risk. The principal risks we have identified, and the steps we take to manage them, are set out below.

5. Due diligence and remediation

Our most significant and effective due-diligence control is our safer-recruitment process, which applies to every worker before they are deployed and is maintained throughout their engagement. No worker is added to our deployable workforce until every check is complete, verified and recorded.

Verified right-to-work checks in line with Home Office requirements;
Identity verification and confirmation that the worker is paid into their own, individual bank account;
Enhanced DBS checks appropriate to the role;
A minimum of two references, with employment-history gaps explored and explained;
Payment of at least the National Minimum / National Living Wage, with accurate and timely payroll;
Clear written terms of engagement and fair working arrangements, including rest breaks and working time compliance.

5.1 Responding to concerns (remediation)

Any worker, person we support, family member or member of the public can raise a concern about modern slavery, and we encourage them to do so without fear. Concerns are taken seriously, treated as a safeguarding matter, and acted upon immediately. Where modern slavery is suspected, we will support the potential victim, work with the relevant local authority safeguarding team and the police as appropriate, and may make a referral through the National Referral Mechanism. We protect those who raise concerns in good faith under our Whistleblowing Policy, and the Modern Slavery & Exploitation Helpline (08000 121 700) is available to staff as an additional route.

6. Training and awareness

We raise awareness of modern slavery across our workforce so that our people can recognise the signs and know how to act. Modern-slavery and exploitation awareness is included within our safeguarding training, which forms part of every member of staff’s mandatory induction and is refreshed regularly. Staff in recruitment, coordination and management roles receive role-appropriate awareness of the specific recruitment- and labour-related risks relevant to their responsibilities, so that risk indicators are recognised at the points where they are most likely to appear.

7. Monitoring effectiveness

We measure the effectiveness of our approach using practical indicators appropriate to the size and nature of our business. These include:

The proportion of workers with fully complete pre-employment compliance before deployment (target: 100%);
Confirmation that all workers are paid at or above the National Minimum / National Living Wage into their own bank account;
Completion rates for safeguarding training (which includes modern-slavery awareness);
The number of modern-slavery concerns raised, and evidence that each was handled appropriately;
The maintenance of audited, up-to-date personnel files available for inspection.

Findings are reviewed by senior management and reported to the Board as part of our annual review of this

statement, and any lessons learned are used to strengthen our controls.

8. Approval and sign-off

This statement is published with regard to section 54 of the Modern Slavery Act 2015 and constitutes Tinywell Healthcare Services Limited’s voluntary slavery and human trafficking statement for the financial year ended 30 April 2026. It has been approved by the Board of Directors and will be reviewed and republished annually. It is published on the Company’s website and made available to commissioners, partners and members of the public.