Purpose and commitment
Bubble Fresh (Bubblefresh Limited, company number 12691029) is committed to preventing modern slavery, human trafficking, forced labour, and all forms of exploitative labour practices across our operations and supply chain. While we are not legally required to publish a statement under Section 54 of the Modern Slavery Act 2015 (as our annual turnover is below the £36 million threshold), we voluntarily publish this statement each year to promote transparency, uphold human dignity, and support ethical employment. This statement covers the financial year ending in 2025 and has been approved by Lance James, Director of Bubblefresh Limited. It is published on our website in line with Section 54 best practice.
Board-level responsibility
Lance James, Director of Bubblefresh Limited, has overall responsibility for this statement and for ensuring that modern slavery has no place in our business. The Director personally reviews and signs off this statement each year before publication. The Director is also responsible for ensuring that our policies, procedures, training, and due diligence measures are effective in preventing modern slavery. Any concerns escalated under this statement are reviewed directly by the Director.
Our structure and operations
Bubblefresh Limited is a UK-registered company based in Rushden, Northamptonshire. We provide specialist cleaning, decluttering, deep cleaning, and related support services for vulnerable adults, families, and local council partners across Northamptonshire, Milton Keynes, Bedford, and Norfolk. We employ our staff directly on permanent or fixed-term contracts and do not currently use subcontractors, agency workers, or engage in external labour sourcing. Should we expand or engage third-party labour in the future, we will carry out due diligence before any engagement begins and include modern slavery clauses in all contracts.
Our supply chain
Our supply chain is relatively small and mainly UK-based. It includes cleaning products, personal protective equipment (PPE), waste disposal services, vehicle maintenance, and IT services. We recognise that modern slavery risks can exist in supply chains, including in the manufacture of cleaning chemicals, PPE, and textiles. We expect all our suppliers to share our commitment to preventing modern slavery and to comply with the Modern Slavery Act 2015. We give preference to UK-based suppliers where possible to reduce the risk of labour exploitation in overseas manufacturing. Where we source products that may have complex international supply chains (such as PPE or cleaning chemicals), we ask suppliers to confirm in writing that they have taken reasonable steps to ensure their own supply chains are free from modern slavery.
Supply chain due diligence
We carry out proportionate due diligence on our suppliers. For new suppliers, we ask them to confirm their compliance with the Modern Slavery Act 2015 before we place any order. For existing suppliers, we review their modern slavery position as part of our annual supplier review. Where a supplier is required to publish a modern slavery statement under Section 54, we check that the statement is current and published on their website. We will not knowingly work with any supplier that fails to take reasonable steps to prevent modern slavery. If we identify concerns about a supplier, we will raise the issue with them directly. If the supplier does not take appropriate action, we will end the relationship and find an alternative.
Our policies
We have a range of policies that support our commitment to preventing modern slavery. Our recruitment process ensures fair, lawful, and voluntary employment for all staff. This includes right-to-work checks for all employees, Disclosure and Barring Service (DBS) screening (Basic and Enhanced where required), professional reference checks, and verification that no fees are charged to workers at any stage of recruitment. We pay at least the National Living Wage as set under the National Minimum Wage Act 1998 and ensure working hours comply with the Working Time Regulations 1998. Related policies include our Safeguarding Policy (which sets out our duty to protect vulnerable adults), our Whistleblowing Policy (which provides a safe route for reporting concerns), our Equality and Diversity Policy (which ensures fair treatment of all workers), and our Training and Development Policy (which covers mandatory modern slavery training for all staff).
Risk assessment
We have identified the following areas of modern slavery risk relevant to our business. First, the cleaning industry is identified by the Gangmasters and Labour Abuse Authority (GLAA) as a sector with higher risk of labour exploitation, particularly where agency labour or subcontracting is used. While we employ all staff directly, we remain alert to this risk. Second, our staff work in domestic settings with vulnerable adults, some of whom may themselves be victims of modern slavery, trafficking, or exploitation. Staff may encounter signs of trafficking, forced labour, or domestic servitude while carrying out their work in people's homes. Third, our supply chain includes products (cleaning chemicals, PPE, textiles) that may originate from countries or industries with known modern slavery risks. We assess these risks regularly and update our controls accordingly. We carry out risk assessments for each site visit, maintain lone working protocols with mandatory check-ins, and provide training to help staff recognise signs of exploitation affecting both colleagues and clients.
Recognising modern slavery in clients' homes
Because our staff work inside people's homes, they may come across signs that a person living there is being exploited or trafficked. We train all staff to be alert to indicators of modern slavery in domestic settings, including signs that someone is being controlled by another person, people who appear frightened, withdrawn, or unable to speak freely, evidence that someone is not free to leave the property, signs of people living in cramped or unsuitable conditions, individuals who appear malnourished or have untreated injuries, and situations where someone else controls a person's documents, money, or phone. If a member of staff has any concern that a person they encounter during their work may be a victim of modern slavery, they must report it immediately in line with our reporting procedures. We will never ignore a concern, and we will always act. Staff are trained to respond safely without putting themselves or the potential victim at risk. Our Safeguarding Policy sets out the full procedure for raising and escalating concerns about vulnerable adults.
Due diligence in recruitment
We conduct thorough due diligence during recruitment to prevent modern slavery within our own workforce. This includes verifying the right to work in the UK for all staff using original documents, checking that no recruitment fees have been charged to workers at any stage, confirming that all workers have entered employment voluntarily, ensuring that workers retain their own identity documents at all times, and checking references and employment history. We do not use recruitment agencies. If we do so in the future, we will require agencies to confirm their compliance with the Modern Slavery Act 2015 and the Employment Agencies Act 1973 before any engagement. We also check that workers' bank accounts are in their own name and that wages are not paid to a third party, as this can be an indicator of exploitation.
Training
All staff receive modern slavery awareness training during their induction, as set out in our Training and Development Policy. Training covers how to identify signs of modern slavery and human trafficking (including indicators such as restricted freedom of movement, withheld documents or wages, signs of control and coercion, exhausting working hours, isolation from support networks, untreated medical conditions, and signs of physical or psychological abuse), how to recognise signs of exploitation in clients' homes (see the section on recognising modern slavery in clients' homes above), understanding right-to-work regulations and ethical recruitment, the National Referral Mechanism (NRM) as the formal pathway for identifying and supporting victims, the role of the Gangmasters and Labour Abuse Authority (GLAA), and procedures for reporting concerns both internally and externally. Managers and staff working directly with vulnerable clients receive additional training, including the difference between the NRM and the Duty to Notify under Section 52 of the Modern Slavery Act 2015. We provide annual refresher training for all staff and keep records of who has completed training and when.
Working with council partners
We work closely with our council partners to prevent and respond to modern slavery. Our council contracts include commitments to ethical employment practices. Where a council partner has its own modern slavery protocol, we follow it alongside our own procedures. If our staff identify a potential victim of modern slavery during work carried out on behalf of a council, we notify the relevant council safeguarding team immediately, in addition to following our own reporting and referral procedures. We share relevant information with council partners in accordance with our Privacy Policy and applicable data-sharing agreements.
Reporting concerns
We encourage all staff, clients, council partners, and members of the public to report any concerns related to modern slavery. Reports can be made confidentially to management on 01933 213045 or at rniqezffpjpcofzcrrymtbweqz@bqeeuxxkbugcbiinlfuaeumofwmdrcqleaovspgxhqkn.bcqcrdioaoq.tyquxhgkshk, or through our Whistleblowing Policy. If you use Relay UK, call 18001 then 01933 213045. We take all reports seriously and investigate them promptly. We protect anyone who raises a concern in good faith from any penalty or unfavourable treatment. If you have concerns about modern slavery related to our services, contact us on 01933 213045. Our registered office is 6 Carnegie Street, Rushden, Northamptonshire, NN10 9SN. You can also report concerns to the Modern Slavery Helpline on 08000 121 700, run by Unseen and available 24 hours a day, 7 days a week. In an emergency, always call 999.
Remediation
If we discover or suspect modern slavery in our operations or supply chain, we will act immediately. Within our own workforce, we will ensure the safety of the person affected, report the matter to the police and the Modern Slavery Helpline, make a referral to the National Referral Mechanism (NRM) or complete a Duty to Notify form under Section 52 of the Modern Slavery Act 2015, support the person affected to access appropriate help (including the support provided through the NRM, such as safe accommodation, legal advice, and access to medical care), and investigate the circumstances fully. Within our supply chain, we will raise the concern with the supplier and require them to investigate and take corrective action. If the supplier does not respond appropriately, we will end the relationship. We will never knowingly benefit from modern slavery. We will cooperate fully with law enforcement and any statutory investigation.
Measuring effectiveness
We track the following measures each year to assess whether our approach to preventing modern slavery is working: the percentage of staff who have completed modern slavery awareness training (target: 100%), the number of concerns raised by staff relating to modern slavery (we track this to understand awareness, not to set a target for a specific number), the number of referrals made to the NRM or via Duty to Notify, the completion rate for supplier due diligence checks, the number of suppliers asked to confirm compliance with the Modern Slavery Act 2015, and whether any instances of modern slavery have been identified in our operations or supply chain. We report these measures to the Director annually and use them to identify areas for improvement. We publish a summary of these measures in our annual modern slavery statement.
Annual publication
We publish this statement on our website each year within six months of our financial year end. The statement is approved and signed by the Director before publication. We keep previous years' statements available on our website so that our progress can be tracked over time. This is our first voluntary modern slavery statement.
Changes to this statement
We may update this statement from time to time. Any changes will be posted on this page with an updated date. Where we make material changes to our approach to preventing modern slavery, such as changes to our supply chain due diligence, risk assessment, or reporting procedures, we will notify affected parties including staff, council partners, and suppliers directly and highlight these changes in the next annual statement.
Review
The Director, Lance James, reviews this statement annually or sooner if we begin subcontracting services, significant legislative or operational changes occur, or identified risks change. Lance James is responsible for ensuring the implementation and monitoring of this statement. Last reviewed: February 2026. Next review due: February 2027.