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Modern Slavery Policy

A. Purpose:

This statement sets out Performance Health's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. As part of the procurement of medical devices, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

B. Scope:

The scope of our activities are the manufacture, sale and distribution of medical devices, assistive technology and aids for daily living. The project management of new product introduction from control of design services to release and support of manufactured product. (Ref. PM LRQA ISO 9001-13485 Certificate).

C. Responsibility:

The Managing Director has overall responsibility for the implementation of this policy. Responsibility within the organisation related to anti-slavery is as follows…

  • Policies: Human Resources and Quality & Compliance
  • Risk assessments: Quality & Compliance
  • Investigations/due diligence: Quality & Compliance
  • Training: Quality & Compliance and Human Resources.

Organisational structure and supply chains

This statement covers the activities of Performance Health: Supply Chain Organisation Structure

Countries of operation and supply

The organisation currently operates worldwide.

The company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking by reference to the Business Social Compliance Initiative list of countries at risk from potential ethical standards. This identified our Chinese vendors as a being within a risk country. (See section on due diligence below).

Relevant Policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy - The 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 malpractice and impropriety. This policy is intended to cover concerns which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures e.g. disciplinary. (Ref: Whistleblowing Policy December 2017).
  • Code of Business Ethics and Conduct - The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. (Ref: Code of Business Ethics and Conduct December 2017)
  • Business Quality Manual - The organisation has a social accountability policy to address slavery and human trafficking risks. (Ref: Business Manual issue 20).There is a requirement for suppliers to respect our ethical standards and meet standards of employment, anti-discrimination, working hours, pay, and freedom of association.
  • New Product Proposal Process - The organisation's due diligence and reviews include the completion of the New Product Information Form for each supplier. (Ref: MKT-F-01 rev18 New Product Information Form).

Due Diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include joining SEDEX (Supplier Ethical Data Exchange) to assist our responsible purchasing. As China has been identified as a risk country, our key Chinese vendors have been sent SEDEX questionnaires and added to our SEDEX online assessment profile. (See reference documents).

Awareness-raising programme

The organisation will raise awareness of modern slavery issues by posting a copy of this statement on Company notice boards and highlighting the issue of modern slavery to new staff as part of our induction process. All staff have been issued with a copy of the Code of Business Ethics and Conduct.

Reference Documents available on request from the Q & C Manager:

  • Performance Health LRQA ISO 90001/13485 Certificate
  • Whistleblowing Policy
  • Code of Business Ethics and Conduct
  • Business Quality Manual
  • New Product Information Form
  • Empowering sustainable and ethical supply chains Sedex, the Supplier Ethical Data Exchange, is a not for profit membership organisation dedicated to driving improvements in responsible and ethical business practices in global supply chains. Sedex helps members tackle forced labour in their supply chain. – See www.sedexglobal.com

Board Member approval

This statement has been approved by the organisation's Board of Directors, who will review and update it annually.