Bupa Modern Slavery Act Statement

Bupa’s Modern Slavery Act statement for the financial year ending 31 December 2020

This statement has been published in accordance with section 54 of the Modern Slavery Act 2015 and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015.

This statement applies to the Relevant Entities named on page 10. Introduction

As a business we support the goals of the UK’s Modern Slavery Act About Bupa and we have a zero tolerance approach to forced labour of any kind. We are an international healthcare company serving over 31 million customers worldwide. Bupa is committed to being a responsible and sustainable business. As a global healthcare company, we recognise that businesses can play an With no shareholders, our customers are our focus. We reinvest important role in protecting human rights and have a responsibility to profits into providing more and better healthcare for the benefit of respect and promote them within their sphere of influence. current and future customers.

Modern slavery in all its forms, including human trafficking, forced labour Health insurance accounts for 17.9m customers and contributes and servitude, are crimes against people and responsible for untold misery 72% of our revenue. In health provision, we operate clinics, dental and suffering. Bupa remains committed to combating the real and growing centres and hospitals in some markets serving another 13.6m problem of modern slavery. We recognise it can affect any industry and we customers. We also care for around 20,000 residents in our aged take seriously our responsibility to be alert to the risks in our business and care businesses in the UK, Australia, New Zealand and Spain. in our wider value chain. We directly employ around 84,000 people, principally in the UK, We expect our people, partners, and suppliers to share our commitment to Australia, Spain, Chile, Poland, New Zealand, Hong Kong SAR, ensuring modern slavery does not exist in any area of our business. Turkey, Brazil, Mexico, the US, Middle East and Ireland. We also have associate businesses in Saudi Arabia and India.

This document outlines the action taken by those Bupa entities1 required to make a transparency statement pursuant to the Modern Slavery Act to help ensure that we, working together with our partners and suppliers, can meet that commitment.

1 Relevant Entities and other defined terms used in this document are shown on page 10.

Modern Slavery Act statement 2 Modern slavery risk within Bupa’s ESG agenda

Through 2020, we maintained a focus on environment, social impact and governance (ESG) considerations in how we responded to the pandemic and more broadly.

The management of our ESG agenda is Environment & Climate Action embedded into our wider governance to Programme Responsible Business Conduct ensure we manage it in an integrated Oversees the development and Bupa has a role to play in the economies way. delivery of our decarbonisation and and societies in which we operate which sustainable includes a responsibility to ensure we A Group Board Sustainability Committee resource usage agenda conduct our business activities was established in April 2021 to assist appropriately. the Board and its other Committees in Responsible Business Conduct & ensuring the integrated management of Reporting We are committed to operating in a fair and ESG matters. Ensures governance, horizon-scanning transparent manner and in accordance with and consistency of external reporting of the law, including combating the real and During 2020 we strengthened our material themes at an growing problem of modern slavery. approach to the fundamentals of Enterprise level Responsible Business Conduct, Our commitment is underpinned through increasing governance and reporting in Sustainability our Bupa Code, our Bupa Values and our this area. We are developing plans for a & Corporate Affairs Executive Team robust risk management framework which new level of ambition on Environment Focuses on the delivery of ESG seek to create both the right culture and and Climate Action. activation in businesses, and leads appropriate governance to hold ourselves advocacy and to account. social contribution Modern Slavery Act statement 3 Our practices and policies

Bupa’s Enterprise Policy suite The Bupa Group has a number of policies and codes that are relevant to tackling modern defines the overarching principles slavery with respect to its business and suppliers: for how the Group manages risk in key business areas; meets The People Policy sets out Bupa’s aim to promote a workplace environment that is fair, open and business objectives; and complies respectful, and one that protects the rights and dignity of all employees. The Bupa Group operates with legal and regulatory people practices, contracts of employment and collective agreements that are lawful and aligned to requirements. Enterprise Policies the Bupa Code and values. are approved by Executive and Board committees to ensure they The Bupa Code applies to all of Bupa’s people and requires that everyone is treated with respect define the minimum expectations and dignity. It makes it clear that Bupa people follow all applicable laws, regulations, policies, and around how we do business. standards, and that people are enabled and expected to speak up. Enterprise Policies apply to the Bupa Group, including the The Speak Up Policy sets out the Group’s commitment to ensuring people are free to question Relevant Entities, and all things and raise anything they are concerned about (including breaches of the Bupa Group businesses are expected to Enterprise Policies). The Speak Up Enterprise Policy specifically calls out modern slavery and comply with the principles and human trafficking as examples. The Speak Up phone line can take queries and concerns in 150 requirements of all applicable different languages and is available across the Bupa Group. The Speak Up phone line can be used policies. by suppliers or indeed any individual wishing to raise a concern relating to Bupa. In 2020, no calls were received through Speak Up that were categorised as relating to modern slavery. More information about Bupa’s risk management activities can be The Suppliers Policy sets out the Bupa Board’s expectation that the Bupa Group has effective found in the 2020 Annual Report processes for the selection of, contracting with and management of direct suppliers, allowing the and Accounts. Group to manage the risks posed by these suppliers throughout the supplier relationship lifecycle.

Modern Slavery Act statement 4 Identifying modern slavery risk within our business

Identifying risk within our operations

We undertake an annual self-assessment of our Drawing on action in 2019 to People practices to monitor and improve our strengthen our risk assessment approach to managing the risk of modern processes, we identified areas of slavery and human trafficking occurring in our potential modern slavery risk exposure own operations. in each business area. In response, we issued targeted communications to The survey targets our approach to recruitment, raise awareness in our Care Services use of agency and temporary workers, on- business. boarding of new employees and terms and conditions of employment. We developed plans to undertake In 2020, the assessment confirmed that we have assurance reviews designed to focus good practices in place. The design of on our People processes and hiring recruitment processes and, the controls in place practices across the Bupa Dental and for pre-employment screening help minimise the Care Services businesses. Although risk of modern slavery occurring within our timing was impacted by the pandemic, business. These processes and controls include we were able to undertake the review checks on individuals’ right to work in the UK, of our Dental business in late 2020 prior employment screening and ensuring that which found that the inherent risk of contracts with agencies use Bupa’s standard contravening the Modern Slavery Act is terms and conditions. low for that business.

Modern Slavery Act statement 5 Identifying risk within our direct supply chain

The Bupa Group’s supply chains are annually to ascertain any gaps and to We assess these suppliers using a risk both local and global, with a total ensure that these are resolved. matrix considering modern slavery risk annual spend in goods and services of that takes account of the supplier’s £2.2bn with more than 23,000 This is evaluated by our Procurement location (in the case of goods) and the suppliers. In 2020, the spend for the team in consultation with our Legal, location in which the supply is delivered Relevant Entities was £800m with Risk and CRS teams. The questions (in the case of services) and also the c.8,000 suppliers. focus on whether the suppliers have sector in which the supplier operates. whistle-blowing policies in place, We recognise there are many whether they require similar policies of For 2020, we identified 54 suppliers to challenges that we, in common with their own suppliers, and whether any the Relevant Entities as potentially high other large organisations, face in full concerns that could be considered risk and who are being assessed transparency across each tier of our connected to modern slavery and/or through this process. supply chain. At present, we are only human trafficking are reported using able to carry out meaningful due these arrangements. diligence on those who supply goods and services directly to Bupa. In addition, we conduct an annual modern slavery check on those Our due diligence processes are set up suppliers who we consider to be high to issue any prospective suppliers with risk and for whom we do not hold a a modern slavery risk assessment recent supplier risk assessment questionnaire. We undertake a (completed within the last 12 months). retrospective review of this activity

Modern Slavery Act statement 6 The impact of COVID-19 on modern slavery risk

The COVID-19 pandemic has heightened Across our operations, we did not our awareness of the risk of modern compromise existing standards of due slavery through increased demand on diligence as a result of COVID-19. In our the manufacturers and suppliers of operations, we ensured that hiring and goods and services that support the recruitment due diligence processes health and wellbeing of our customers, remained intact for the entities that employees, and communities. introduced fast-tracked screening to As the full extent of the social and recruit frontline workers. economic consequences of COVID-19 Throughout the pandemic, we remained are still to be fully understood, we vigilant to potential COVID-19-related In our supply chain, we used existing remain committed to monitoring and risks relevant to our stance on modern suppliers to obtain personal protection mitigating modern slavery risks in our slavery, in line with UK government equipment (PPE) where possible. These operations and supply chain. For more guidelines published in April 2020. No existing suppliers would have already information on our full response to additional modern slavery risks were been subject to our modern slavery due COVID-19, please see our 2020 Annual identified during 2020. diligence processes. Report and Accounts.

Modern Slavery Act statement 7 Action we took in 2020

Increased awareness of modern Conducted an assessment of one of slavery risks and employment practices our primary outsourced services relating to them across our UK aged suppliers based outside of the UK to Bupa Speak Up care businesses, which use agency better understand its employee and other temporary staff on a regular recruitment processes and ensure Bupa Speak Up basis, through targeted our contractual requirements were Speak Up is our confidential channel which communications to care services staff being met. We looked at its training employees, partners and suppliers can use to in Q4 2020, and we undertook an materials and processes to ensure report concerns about things relating to Bupa assurance review of people processes modern slavery risk was well that aren’t, or don’t seem, right, including in our dental clinics business. understood within the organisation. concerns relating to modern slavery.

You don’t have to be a Bupa employee to report an issue which relates to Bupa. After a concern Collaborated and shared best practice Implemented our Responsible is reported, a Speak Up Officer will contact the with our ANZ Market Unit in Supply Chain statement, which reporter via the Speak Up website to discuss preparation for publication of a sets the minimum standards of the concern raised. modern slavery statement for in- business conduct Bupa expects from scope Australian businesses in 2021. its direct suppliers and which need to be applied through our supply Each Speak Up Officer is someone who works chain, including standards relating to for Bupa and their contact details can be found the Speak Up website. the prevention of modern slavery. on

Modern Slavery Act statement 8 Our priorities for the year ahead

• Monitoring the continued impact of COVID- Regulatory developments In 2021, we will focus on 19 on our operations and heightened risk the following priorities: of modern slavery within the supply chain. We have followed relevant regulatory developments to inform our approach to • Extending our supplier due diligence mitigating modern slavery risk, including processes beyond our direct supplier base the UK Home Office guidance for and operations, to include pre-contractual businesses concerning modern slavery and post-contractual monitoring and risks during the COVID-19 pandemic supplier engagement. published in April 2020.

• Strengthen our governance processes In September 2020, the UK Government in light of the regulatory developments published its response to its 2019 concerning the UK’s modern slavery consultation on strengthening the UK legislation. Modern Slavery Act. The changes proposed include making certain matters to • Ensure that modern slavery risk continues be addressed in a modern slavery to be an area of heightened risk awareness statement mandatory, rather than voluntary within the Responsible Business Conduct as presently the case. pillar of our ESG agenda. In February 2021, the Home Office • Focus on aligning modern slavery risk launched a new registry service that allows assessment and operational risk mitigation reporting organisations to voluntarily add best practices between our UK and their modern slavery statements to the Australia businesses, where appropriate. registry. Modern Slavery Act statement 9 The board of The British United Provident Association Limited, as well as the boards of the other Relevant Entities listed below, have approved this statement.

The Group CEO has signed the statement on behalf of The British United Provident Association Limited.

Signed Iñaki Ereño Group Chief Executive Officer 23 May 2021

Defined terms:

In this statement: • Bupa means The British United Provident Association Limited • Relevant Entities means the companies which fall within scope of section 54 of the Modern Slavery Act 2015 and which are named below

• Bupa Group and Group refer to Bupa and its wholly owned and controlled companies • References to we, us and our are to the Relevant Entities

Relevant Entities required to make a statement pursuant to section 54(1) of the Modern Slavery Act 2015:

• Bupa Care Homes (ANS) Limited • Bupa Insurance Services Limited • Oasis Dental Care Limited • Bupa Care Homes (BNH) Limited • Bupa Investments Overseas Limited • Richmond Villages Operations Limited • Bupa Care Homes (CFC Homes) Limited • Bupa Occupational Health Limited • The British United Provident Association Limited • Bupa Finance plc • Medical Services International Limited • Xeon Smiles UK Limited • Bupa Insurance Limited • Oasis Dental Care (Central) Limited

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