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 within 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 workplace and difficulty in recruitment (3) loss of trust with customers and suppliers within the wider society.
  4. Minimum Labour Standards in UK: -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.
  5. 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
  6. Training – Workers shall receive regular and recorded health and safety training, and new employees will receive such training.[WS1] [AM2] 

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.

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.

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 out, 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)


Whistle Blowing

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 

You should telephone the line provided for suppliers’ employees and contractors our confidential hot line on 01623 272597
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.


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.


External Links


Management Representative 

The Brightwake Ltd appointed Management Representative for this Labour Standards Assurance Policy & Management System (LSAS) is a shared responsibility. Each of the below are responsible for the associated role / function relating 

to the management of LSAS: 


Management Representative


Section 6 is encompassed in this section. 


The Brightwake Ltd appointed Management Representative for this Labour Standards Assurance Policy & Management System (LSAS) is a shared responsibility. Each of the below are responsible for the associated role / function relating 

to the management of LSAS: 



Labour standards status review 

The Labour standards are assessed to determine which standards, such as the NHS LSAS and the Ethical Trading Initiative apply Brightwake Ltd and any business partners within our supply chain. 

These reviews are covered during audit and considered during any supplier risk assessments that may be carried out in this regard. 


Legal and other requirements 

It is a Brightwake Ltd requirement that:

 •business unit comply with the relevant employment legislation within their own jurisdiction. 

 • We ensure that, wherever possible, applicable business partners adhere to the LSAS

requirements and apply fair labour practice. 

 • Create internal awareness of the labour standards The sources used to guide Brightwake Ltd in this regard are as below, and will be reviewed on an annual basis to ensure relevance:

 •HSE guidelines (UK)

 GDPR Compliance Checklist

  1. ETI Base Code (& overseas) 
  3. Labour Standards Assurance System 
  4. Safety Health and Welfare Act 2005 
  5. Health and Safety at work act 1974 (as amended 2018)
  6. Bribery Act 2010 
  7. Environmental Protection Act 1990 
  8. Equality Act 2010 (as amended 2012) 
  9. NHS Supply Chain Supplier Code of Conduct 
  10. BMA Ethical Procurement for General Practitioners 
  11. UN’s Universal Declaration of Human Rights
  12. FCPA The Foreign Corrupt Practices Act of 1977


Before any new supplier is approved, they must complete a supplier questionnaire (see FMG 007a)


Objectives, Targets & Programmes

The Objectives have been set out as below. This table will be reviewed on an annual basis and 

updated to reflect the status. 

Roles and responsibilities

Covered in point 2.


Competence, Training and Awareness

LSAS awareness training is given to all relevant employees and records of the training are kept by HR. In line with standard training procedures, should the Policy or requirements be updated, 

updated training / awareness will be issued to all employees.

All members of the LSAS committee will be trained to LSAS level 2 as a minimum.



We have a number of policies to ensure that we are conducting our business with integrity and transparency including our Protected Disclosures Policy. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment because of reporting in good faith their suspicion that modern slavery / a break in the required Labour Standards of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Internal concerns regarding Labour practices would be raised and addressed with our HR Department. Employees are encouraged to report any concerns to HR, including but not limited to:

  • Inappropriate relationships with suppliers 
  • Failure to comply with a legal obligation.
  • A danger of health and safety of an individual 
  • Corruption
  • Bribery


Communication between ourselves and any interested parties within our supply chain, will be done via email. Copies of all correspondence will be kept on record as per our standard Document retention policy.  Should communications covering any concerns regarding Labour Standards be discussed verbally during a meeting, minutes of the meeting are to be kept for reference.

This policy is stored on the company Intranet folder and is available to all employees. 


Documents and Records

All official documents are entered into our QMS or HSMS and managed through our document control module within Q-Man/N&S CCR process This records any change control.


Operational Control

Brightwake Ltd have identified the below as operation control points with regards to Labour Standards:

Supply Chain management

Supply chain management starts with the approval of our Suppliers.

The purchasing department are responsible for sourcing new suppliers and are aware of the requirements to only deal with ethical companies which adhere to good labour practices.

Every new vendor is asked to confirm if they adhere to local/National Labour laws by completing FMG 007a supplier questionnaire.

The country of origin of each supplier is recorded and added to the LSAS supplier risk assessment.


Emergency and Critical Issue Response

All internal issues will be dealt with by the Brightwake Ltd HR department and includes the

implementation of the Modern Slavery’s act document and the whistleblowing policy.

Should Brightwake Ltd become aware of any breach in labour laws & standards from any of our business partners, the following actions will be taken, as applicable:

  1. Business partner communicated in writing and a formal response requested.
  2. Record as non-conformance
  3. Review ETI base code corrective action for guidance on whether the breach is major or minor.
  4. Risk assessment carried out – based on risk, trade with the business partner may besuspended.
  5. They may be removed from the approved supplier list.
  6. Notify the relevant national enforcement office to intervene.


Performance Measuring and Monitoring


The objectives will be reviewed as per the KPI’s laid out in section 5 of this document. This will include the below:

Corrective action

CAPAS are currently recorded within the QMS.

 Any Corrective actions relating to suppliers, will be noted in the annual supplier assessment and reviewed at the Management review.

All CAPAS will be communicated with the relevant party. Once agreed and communicated with a supplier, will be closed off in a timely manner, with supporting evidence and a root cause established:

Major Non-Conformance: Action - Immediate to One Month (dependent on criticality). In severe cases, trade with a supplier may be suspended until corrective measure are taken. Minor Non-Conformance: Action - Within Three Months

Observations: Action - Dependent on issue. Some may not require close out.


Management Review

During the Annual Directors Management Review, LSAS requirements and compliance are discussed and recorded to ensure that the policy is being adhered, requirements are being met and continual improvement with regards to meeting LSAS is considered.