Labour Standards Policy

Brightwake Ltd manufactures and supplies a range of medical devices worldwide.
As a company, the Board of Directors are fully informed of the need for a Labour Standards Assurance Policy and the obligation to our employees, customer, and supplies with in the sector we operate.  For this reason, we are making this policy public knowledge.
Scope of the Policy
Brightwake Ltd has set this policy to cover its supply to the NHS via the Framework Agreement for General and Advanced wound care products
Scale of the Policy
Brightwake Ltd is committed to implement this policy in line with EU law as a SME
 Policy Review and Improvements

Brightwake Ltd will review this policy periodical in line with LSAS policy and legislation changes, any requirements needed to ensure that we have a suitable and effective policy will be adhered to.
Application of Labour Standards, Application of the Code & Laws & Ethical Standards

  1. Minimum Labour Standards – are derived from the Ethical Trading Initiative (ETI) Base Code, which in turn is founded on the conventions of the International Labour Organisation (ILO)
  2. Suppliers – shall comply with all laws applicable to its business locally and nationally.  The supply should adhere to the principles of the United Nations’ Global Impact, UN Declaration of Human Rights as well as the 1998 International Labour Organisation’s “Declaration of Fundamental Principles and Rights at Work” in accordance with National law and practice. The supplier shall ensure conformance to all laws applicable in their nation and locality. Suppliers – are expected to have noted the requirements of the Code and to have established similar arrangements to provide evidence that they are working towards the requirements.
  3. Provisions of Law – where this Code and provisions of law address the same subject, the provision which affords the greater protection shall be applied.
  4. Complying with the Code – companies applying this Code are expected to comply with national, local and other applicable laws.
  5. Workers – are defined as those employed on a temporary basis or permanent basis, as well as workers that are employed either directly or indirectly

Minimum Labour Standard
Brightwake Ltd has identified the following reasons to establish a comprehensive system of Minimum Labour Standards to guide its business operations.

  1. Ethical Responsibilities – the company accepts its obligation to its employees, customers and suppliers with in the sector we work to operate in an ethical manner.
  2. Risk of Supply – Brightwake Ltd has identified that labour standards abuse in supply chain can pose a risk of supply.  Any supply chain partners of Brightwake Ltd committing abuses face legal enforcement action which could damage business and obstruct continue of supply.
  3. Damage to the company’s reputation due to adverse publicity- discovery of labour standards abuse presents a reputation and structural risk (1) Turnover- customers choose to purchase supplies and services from other sources. (2) staff retention and recruitment may be affected as people choose not to work for a company associated with any labour standards abuses; this could also lead to low morale in the work place and difficulty in recruitment (3) loss of trust with customers and suppliers within the wider society.

Objectives and Targets

  1. Labour Standards Assurance – Questionnaires: Brightwake Ltd will request LSAS Questionnaires to be completed for new suppliers, and will revisit and request updated questionnaires at 12-month intervals. Questionnaires are to be completed by Suppliers within 14 days (from date Questionnaire sent).
  2. Non-Conformance –all Labour standards NCR’s will initially be investigated by HR Manager. Reporting findings to Supplier within 14 days of Non-Conformance being raised.

Brightwake Ltd will continue to review and monitor supplier remedial action over a 12-month period from date NCR reported.
If such supplier does not conform with standards required, and does not respond within the 14-day period, the matter will be escalated to the Operations Director to take appropriate action.

  1. Labour Standards Assurance System (LSAS)– achieving required level.

The Health and Safety Manager will take action from January 2022 to collaborate and share resources with other suppliers/organisations that are currently working towards achieving Level 2 (minimum standard).  The Health and Safety Manager will have communicated up-to-date Labour Standards Assurance Policy, and will set up training sessions, meetings, and presentations with internal staff

  1. The company recognises that our suppliers may face challenges in today’s globalised marketplace.  We aim to work with our suppliers openly and honestly.  Where concerns about human rights, labour, environment or ethical issues are identified, we will work with them to make improvements to the issues arising.
  2. NHS Supply Chain non– conformances are recorded and monitored and dealt with immediately as they arise.  For manufacturer non– conformances the Operations Director will contact the supplier to discuss remedial action
  3. Quality of Goods and services – Brightwake Ltd recognise that there is typically a link between labour standards and poor quality of goods and services.  

Procedure for Non-conformance
If a LSAS Non-Conformance on any of our suppliers is reported/documented during the 6-12-month period, Brightwake Ltd will take remedial action by carrying out a risk assessment, and reporting the findings to the supplier with 14 days of the Non-Conformance being raised.
Dependant on the information supplied for any non-conformance, Brightwake Ltd can request the supplier to supply satisfactory supported and signed evidence that they meet minimum Labour Standards requirements, and Brightwake Ltd will continue to monitor and request any other evidence covering a 12-month period from the date of the NCR.
If the supplier does not supply satisfactory evidence/information at any stage during the 12-month period, the matter will be referred to the Operations Director, to escalate the matter, with the potential of any supplier being withdrawn from Brightwake Ltd supplier database.  
A risk assessment is carried, and if any non-conformance is reported within a 12-month period as a result of a status review, supplier appraisal, supplier audit, third party audit, internal audit, external audit, whistle-blowers or other means of communication (Public or Media). 

Brightwake Ltd conducts its business with high standards of integrity and honesty and expects the same standards from all employees, suppliers and contractors.
All employees, suppliers’, contractors should report any concerns or suspicions about any wrongdoing or malpractice, and be assured that the information received will be treated seriously, and where possible, confidentially. 

What to report:

  • A Criminal offence
  • Failure to comply with a legal obligation
  • A danger of health and safety of an individual
  • Dishonesty
  • Corruption
  • Bribery
  • Inappropriate relationships with suppliers
  • False accounting or reporting irregularities
  • A delivery concealment of any of the above matters
  • Information/evidence for reporting of UK and overseas suppliers not adhering to Minimum Labour Standards /ILO Conventions 

Whistleblowing Procedure:
You should telephone the line provided for suppliers’ employees and contractors our confidential hot line on 01623 252597
Once a concern or incident has been reported, Brightwake Ltd will make preliminary enquiries and decide if further investigation is needed.  If so Brightwake Ltd I will be decided whether this should be conducted internally or whether the matter should be referred externally.  Where possible, Brightwake Ltd will advise of the outcome of any investigations.
Any supplier, supplier employee or contractor who does report their concerns will not be victims or treated less favourable in anyway as a result.
Deliberate raising of false or malicious allegations is not acceptable and will be viewed extremely seriously by Brightwake Ltd.
Brightwake Ltd have referred to the following resource documents: -
Social Accountability International SA8000
UN’s Universal Declaration of Human Rights
ETI Base Code
ILO Conventions
The Health and Safety Manager is determined as the author of the Labour Standards Assurance System (with supported evidence provided including:
Online sources, media material, suppliers, NHS Supply Chain, ETI, ILO, Stakeholders and other interested parties.
Minimum Labour Standards in UK: -

  1. Child Labour – Brightwake Ltd does not engage in or support the use of child labour.  If Brightwake Ltd engages any young workers (Work Experience) it will ensure that a suitable risk assessment is carried out and passed to the local education authority, and that NO young person is exposed to any dangerous conditions, or work more than an 8-hour day.
  2. Forced or Compulsory Labour- Brightwake Ltd shall not engage in or support the use of forced or compulsory labour, or bonded or involuntary prison labour.  Employees are free to leave upon reasonable notice.
  3. Freedom of Association and Collective Bargaining – workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
  4. Health & Safety – Brightwake Ltd shall provide a safe and healthy workplace environment and shall take effective steps to prevent potential accidents and injury to employee’s health by minimizing the risk to its employees.  All employees will receive safety and job training during their employment.  Employees will have access to clean toilet facilities and drinking water plus a canteen area to consume food and drink.  The health and safety responsibilities of Brightwake Ltd have been assigned to the Health and Safety Manager
  5. Training – Workers shall receive regular and recorded health and safety training, and new employees will receive such training.

Employees will receive regular training aligned with their respective occupation of employment (as and when necessary).  All training will be documented, and reference made on staff personnel files.

  1. Environmental – Brightwake Ltd is committed to protecting the environment both through our own actions and also by working with our suppliers.  We will continue to focus on delivery high standards of service and quality of goods to our customers.  We will comply with all regulatory and legislative requirements to protect the environment.
  2. Discrimination – Brightwake Ltd will not engage or support any form of discrimination in its employing of staff, salary, training, promotion, termination or retirement based on race or national or social origin, caste, religion, gender, sexual preference, political affiliations, age or other circumstance that could be classed as discrimination.
  3. Disciplinary Practices – Brightwake Ltd will treat all employees with dignity and respect.  Brightwake Ltd shall not or tolerate the use of corporal punishment, mental or physical bullying or verbal abuse of personnel.  No cruel or inhumane treatment is allowed.
  4. Working Hours – Brightwake Ltd shall comply with relevant laws and labour standards on working hours and holiday entitlement.  Brightwake Ltd working hours do not exceed 48hours per week and overtime hours do not exceed 12 hours per week.  Brightwake Ltd ensure that all employees have the legal right to be employed in the UK.
  5. Remuneration- Brightwake Ltd shall comply with national laws and regulations relating to wages and benefits.  All work associated activities are carried out on the basis of a recognised employment relationship established according to national law and practice.

Commitment to Continual Improvement
Brightwake Ltd is committed to ensuring the achievement and improvement in all areas of its business.
Our approach to continuous improvement will be underpinned by providing a high-quality service, value for money and maintaining and monitoring performance, whilst administering continual improvements throughout the company.
This Policy will be subject to updates and amendments, as and when necessary.  For internal measures the Policy will be reviewed at 6-monthly intervals.

Brightwake Ltd is also committed to: -

  • To be compliant with other relevant legal requirements for our Notifiable body
  • Ensure that key contractors, sub-contractors and suppliers are aware of this policy
  • Make available time and resource for the implementation of this policy
  • Ensuring that our suppliers, in particular overseas suppliers, adopt labour practices including a fair and honest approach to their employees and anyone whom they trade with
  • Brightwake Ltd recognises the importance of corporate responsibility towards sustainable objectives and of maintaining high standards of social, ethical and environmental conduct
  • Brightwake Ltd has built in contingency plans for Business Continuity – these are reviewed on a 6-12 month basis
  • Brightwake Ltd is continually building in capacity for carbon reduction, enforcing recycling processes (as far as possible) and managing the amount of waste that the company produces
  • Brightwake Ltd are innovative with their product design and can deal with bespoke customer requirements.  Therefore, allowing the customer to be provided with their specific requirements, thus reducing wastage, whilst maintaining an affordable and quality product

We will make the policy public via our website and be communicated to Brightwake Ltd employees and all contractors, sub-contractors and suppliers.

Whistleblowing Procedure

Policy Statement & Purpose

1. Brightwake Ltd is committed to conducting our business with the highest standards of openness and accountability.

An important aspect of accountability and transparency is a mechanism to enable staff and other members of the Company to voice concerns in a responsible and effective manner. It is a fundamental term of every contract of employment that an employee will faithfully serve their employer and not disclose confidential information about the employer’s affairs. Nevertheless, where an individual discovers information which they believe shows serious malpractice or wrongdoing within the organisation then this information should be disclosed without the fear of reprisal, and there should be arrangements to enable this to be done independently of line management.

The purpose of this policy is:

  • To encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.
  • To provide staff with guidance as to how to raise those concerns.
  • To reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

2. Employees have legal protection against being dismissed or subjected to detrimental treatment as a result of raising a genuine concern. The Company has endorsed the provisions set out below to ensure that no members of staff should feel at a disadvantage in raising genuine concerns.

3. It should be emphasised that this policy is intended to assist individuals who believe they have discovered wrongdoing in the workplace. It is not designed to question legitimate financial or business decisions taken by the Company nor should it be used for complaints relating to staff member's own personal circumstances, such as the way they have been treated at work. In those cases, the Grievance Procedure should be used.

4. This policy is designed to enable employees of the Company to raise concerns internally and, at a high level and to disclose information which the individual believes shows wrongdoing. Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers and could include:

  • Financial malpractice or impropriety or fraud
  • Failure to comply with legal obligation or Statutes
  • Dangers to Health & Safety or the environment
  • Criminal activity
  • Improper conduct or unethical behaviours
  • Attempt to conceal any of these


5. This policy is designed to offer protection to all employees, officers, consultants, contractors, casual workers and agency workers of Brightwake Ltd who raise a genuine concern about any of the above.


6. Brightwake Ltd will treat all such disclosure in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential as long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual may need to provide a statement as part of the evidence required.

Anonymous Allegations

7. We hope that staff will feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate and as such we encourage individuals to put their name to any disclosures they make. We will make every effort to investigate anonymous disclosures. Proper investigation may be more difficult or impossible if we cannot obtain further information from the person who raised the concern. It is also more difficult to establish whether any allegations are credible.

Untrue Allegations

8. If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If we conclude that a complainant has made false allegations maliciously, the complainant will be subject to disciplinary action.

To make a disclosure

9. We hope that in many cases staff will be able to raise any concerns with their manager. However, where the individual prefers not to raise it with their manager for any reason, they should raise it by calling the internal Whistleblower Hotline on 01623 272597. The complainant should leave a message if the call isn't answered as the messages will be checked regularly.

Dealing with complaints

10. On receipt of a complaint of malpractice, this information will be passed on, as soon is reasonably possible, to the appropriate designated investigating office as follows:

  • Complaints of malpractice will be investigated by the appropriate Director unless the complaint is against the Director or is in any way related to the actions of the Director. In such cases, the complaint should be passed to the Managing Director for referral.
  • In the case of a complaint, which is connected with but not against the Director the Managing Director will nominate a Senior Manager or external party to act as the alternative investigating officer.
  • Complaints against the Managing Director should be passed to the Chairman who will nominate an appropriate internal / external investigating officer.
  • If the complaint is submitted in an alternative manner (i.e., not using the number above) and bypasses the line management structure the recipient of the complaint has the right to refer the complaint back to management if they feel that the management without any conflict of interest can more appropriately investigate the complaint.

11. If there is evidence of criminal activity then the investigating officer should inform the police. The Company will ensure that any internal investigation does not hinder a formal police investigation.

12. Due to the varied nature of these sorts of complaints, which may involve internal / external investigators and / or the police, it is not possible to lay down precise timescales for such investigations. The investigating officer should ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations.

13. The investigating officer, should as soon as practically possible, send a written acknowledgement of the concern to the complainant and thereafter report back to them in writing the outcome of the investigation and on the action that is proposed. If the investigation is a prolonged one, the investigating officer should keep the complainant informed, in writing, as to the progress of the investigation and as to when it is likely to be concluded.

14. Investigating Procedure – The investigating office should follow these steps:

  • Full details and clarification of the complaint should be obtained.
  • The investigating officer should inform the member of staff against whom the complaint is made as soon as is practically possible.
  • The investigating officer should consider the involvement of the Company auditors and the Police at this stage and should consult with the Managing Director / Chairman if appropriate.
  • The allegations should be fully investigated by the investigating officer with the assistance where appropriate, of other individuals / bodies.
  • A judgement concerning the complaint and validity of the complaint will be made by the investigating officer. This judgement will be detailed in a written report containing the findings of the investigations and reasons for the judgement. The report will be passed to the Managing Director or Chairman as appropriate.
  • The Managing Director or Chairman will decide what action to take. If the complaint is shown to be justified, then they may invoke disciplinary action or other appropriate Company procedures.
  • The complainant should be kept informed of the progress of the investigations and, if appropriate, of the final outcome. However, sometimes the need for confidentiality may prevent us providing specific details of the investigation, an outcome or any disciplinary action taken as a result. The complainant should treat any information about the investigation as confidential.
  • If appropriate, a copy of the outcomes will be used to enable a review of Company procedures.

15. If the complainant is not satisfied that their concern is being properly dealt with by the investigating officer, they have the right to raise it in confidence with the Managing Director or Chairman, or one of the designated persons described above.

External Disclosures

  • The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases staff should not find it necessary to alert anyone externally.
  • The law recognises that in some circumstances it may be appropriate for complainants to report their concerns to an external body such as a regulator. It will very rarely if ever be appropriate to alert the media. We strongly encourage complainants to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Protect, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern. Their contact details are at the end of this policy.
  • Whistleblowing concerns usually relate to the conduct of our staff, but they may sometimes relate to the actions of a third party, such as a supplier or service provider. In some circumstances the law will protect complainants if they raise the matter with the third party directly. However, we encourage staff to report such concerns internally first, in line with this policy.

You should telephone the line provided for suppliers’ employees and contractors our confidential hot line on 01623 252597
Once a concern or incident has been reported, Brightwake Ltd will make preliminary enquiries and decide if further investigation is needed. If so Brightwake Ltd I will be decided whether this should be conducted internally or whether the matter should be referred externally. Where possible, Brightwake Ltd will advise of the outcome of any investigations.
Any supplier, supplier employee or contractor who does report their concerns will not be victims or treated less favourable in anyway as a result.
Deliberate raising of false or malicious allegations is not acceptable and will be viewed extremely seriously by Brightwake Ltd.

Contact Details

Brightwake Whistleblowing hotline

01623 272597

(Independent whistleblowing charity)

 Helpline: 020 3117 2520