Health Bridge Limited: Transparency in Supply Chains Statement for the Financial Year Ending 31 December 2025
This Transparency in Supply Chains statement is made by Health Bridge Limited, trading as Zava (the “Company” or “our”), in compliance with its obligation under s.54 of the UK Modern Slavery Act 2015. This statement sets out the steps the Company has taken in our last financial year (FY2025) to ensure modern slavery and human trafficking is not occurring in our business or supply chains.
Introduction
Modern slavery is a crime and a violation of fundamental human rights. The Company opposes all forms of human rights breaches, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in its business dealings and relationships and to implementing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chains.
The Company is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. The Company expects the same high standards from contractors, suppliers and other business partners and, as part of these contracting processes, includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect that our suppliers will hold their own suppliers to the same high standards.
The Company reserves the right to terminate business with any supplier, contractor, vendor, or business partner in its supply chain that fails to comply with applicable laws and regulations.
Our Business
The Company is a fully integrated digital healthcare provider. It connects customers with doctors through a digital platform, enabling consultations with doctors, prescriptions for any necessary medicines from such consultations, and follow-ups without the need for in-person visits. The Company’s services are currently available to patients in the United Kingdom.
Our Policies
The Company maintains a number of internal policies and procedures that are relevant to its approach to identifying and preventing modern slavery. These include:
- Anti-Slavery and Human Trafficking Policy;
- Standards of Conduct;
- Fit and Proper Person Requirement;
- Whistleblowing Policy;
- Bribery and Corruption Policy; and
- Money Laundering Policy.
Policies are communicated to employees as part of the Company’s induction process.
We note in particular:
The Anti-Slavery Policy
The Anti-Slavery Policy sets out the Company’s zero tolerance approach to modern slavery and its commitment to acting ethically and with integrity in its business dealings and relationships, and to implementing systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
The policy applies to all staff working for the Company or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. Training on the Anti-Slavery and Human Trafficking Policy forms part of the induction for all new joiners. The Company’s zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of the business relationship.
The Whistleblowing Policy
The Company’s Whistleblowing Policy includes a clear escalation process for employees and contractors to raise concerns relating to the Company’s business practices, which includes crimes of slavery and human trafficking. The Company uses only specified, reputable employment agencies to source temporary or permanent employees and always verifies the practices of the agency through the Supplier Portals.
No reports indicating actual or potential modern slavery or human trafficking were reported in FY2025.
Assessing and Managing Risk
The Company does not manufacture or produce pharmaceutical products, nor does it engage overseas-based medical practitioners to deliver its services. The Company's workforce is located in the United Kingdom, a jurisdiction that is assessed as low-risk for modern slavery under internationally recognised indices such as the Global Slavery Index.
It has suppliers located in the UK, USA, Germany, France, Ireland, Australia, Canada, Spain, Sweden, Singapore, New Zealand, Czech Republic, Netherlands, Turkey, and South Africa. The non-UK or Ireland suppliers predominantly provide IT and cloud infrastructure services, software services, marketing and contractor services, legal services, data analytics, translation services.
Having regard to the nature of the Company's business as a digital healthcare provider, the geographic location of its workforce, and the predominantly service-based and technology-driven character of its operations, the Company has assessed the overall risk of modern slavery occurring within its direct operations as low.
Due Diligence
The Company manages modern slavery risk through its vendor risk assessment procedures, which are designed to identify and evaluate potential risks within its supply chain and business relationships. The Company uses a vendor system to manage risks related to vendors and third parties.
As part of its due diligence process, the Company considers factors including the nature of the supplier's services, geographic location, and overall compliance standards prior to engaging with any vendor. The Company undertakes at least annual reviews of its suppliers.
No modern slavery or child labour concerns or red flags have been identified during the conduct of such vendor risk assessment during the course of FY2025.
Employee Training
During FY2025, Company policies and guidance were available to its staff to ensure an appropriate level of understanding of the risks of modern slavery and human trafficking in its business and supply chains.
Awareness on the Company's Whistleblowing Policy, and where to access its modern slavery and related policies forms part of the induction process for all new employees.
The relevant policies are reviewed annually to ensure it remains current and reflects emerging risks. In light of our understanding of the risks faced by the Company, the policies in place and the training provided on those policies, we are confident that there is a very low risk of slavery or human trafficking in the employment or engagement of our own employees.
Monitoring, Evaluation and Future Steps
The Company is committed to continuing to work with its contractors to monitor and identify any emerging risks of slavery and human trafficking in our supply chains; focus on specialist training for employees with responsibility for supply chain management and procurement; and provide induction and refresher training for all employees.
Although no specific slavery or human trafficking has been identified or reported in the last financial year, the Company will continue to monitor and assess potential risks through our vendor risk assessment procedures and ongoing supplier engagement.