Modern Slavery Statement
Introduction
This Modern Slavery and Human Trafficking Statement responds to Section 54(1), Part 6 of the Modern Slavery Act 2015. Modern slavery is a crime and a violation of fundamental human rights. It takes many forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
Kettering Surgical Appliances is committed to preventing slavery and human trafficking in its operations, supply chain, and products. We act ethically and with integrity in all business dealings and relationships, implementing effective systems and controls to ensure modern slavery does not exist within our business or supply chains. We recognize our responsibility to remain vigilant to risks, however small, within our business and supply chain.
Organisational Structure
Kettering Surgical Appliances, based in the United Kingdom, supplies medical goods. We have Recently made changes to our procurement process and policies to address modern slavery and these reflect our commitment to Modern day slavery. We expect the same standards from our suppliers and business partners, including prohibitions against forced, compulsory, or trafficked labour and slavery in any form.
This policy applies to all individuals working for us or on our behalf, including employees, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
Our Status, Operations, and Supply Chain
Kettering Surgical Appliances operates a diverse, small supply chain. We are proud to partner with our suppliers to be able to offer a range of goods, which are imported from around the globe with some being manufactured, on our behalf. A significant number of products are now being manufactured in house, in the UK. As more manufacturing is brought to the UK, we expect to have increased oversight of the process and as a result our risk of modern-day slavery improve with these products.
Current Procurement Policy and Processes
Our procurement policy complies with all applicable UK laws. We consider the risk of modern slavery at every stage of the procurement process and during contract management. All suppliers must comply with our Suppliers & Modern-Day Slavery Policy, this is a requirement of ongoing trade.
Identifying and Managing Risk
With a significant percentage of suppliers based in China, we acknowledge the risk of modern slavery. The presence of high-risk countries in the supply chain of many businesses is unavoidable, however we have taken significant steps to manage this. We manage this risk through increased regular assessments for high-risk countries and collaboration with suppliers to mitigate and improve management of any potential slavery risks.
Due Diligence and Monitoring
Our due diligence and monitoring processes aim to reduce slavery and human trafficking risks by:
Implementing stringent recruitment processes to ensure all employees have the right to work and are employed in fair conditions.
Establishing a dedicated Modern Slavery Act compliance team to monitor and enforce our anti-slavery policies.
Conducting appropriate checks on partner organizations and assessing if price and lead times are reasonable to ensure additional pressure is not placed on suppliers leading to an increased risk of modern-day slavery being used to meet lead times.
Regularly monitoring supplier risks and striving for continuous improvement.
Policies and procedures have been developed around procurement, modern slavery, and suppliers, distributed to stakeholders, and approved by management.
We do not tolerate slavery and human trafficking in our supply chains and will require non-compliant suppliers to remedy any failures.
Managing Risk and Adherence to The Act
Our Supplier and Modern-Day Slavery Policy addresses modern slavery and is distributed to all suppliers, with adherence being a condition of continued business. We expect our supply chain to respect and comply with all applicable laws.
Social Responsibility and Human Rights
Kettering Surgical Appliances is committed to human rights and social responsibility. Our work supports the protection of internationally proclaimed human rights, ensuring our staff, offices, and supply chains are not complicit in human rights abuses.
Training
Our modern slavery training covers:
Identifying signs of slavery and human trafficking.
Initial steps if slavery or human trafficking is suspected.
External help available through organizations like the Modern Slavery Helpline and Gangmasters and Labour Abuse Authority.
Ensuring staff understand how modern slavery manifests and how to report it.
Policies
Our staff have access to annually reviewed and director-approved policies, including:
Child Labour Policy
Human Rights Policy
Employee Code of Conduct
Procurement Policy
Migrant Worker Policy
These policies, along with our measures, aim to prevent modern slavery within our company and supply chains. Staff are encouraged to report concerns directly to management, supported by an appropriate procurement process ensuring supplier compliance.
Next Steps and Key Performance Indicators (KPIs)
In the next financial year and ongoing, we will:
Ensure staff awareness of our commitments through codes of conduct, whistleblowing, complaints, and procurement policies.
Conduct due diligence on new suppliers, proportionate to their size and risk, ensuring compliance with the Modern Slavery Act 2015.
Annually review our supply chain to monitor and assess risks related to slavery and human trafficking.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015, approved by both directors and signed by our Managing Director.
