Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. The company has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. The Company is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

Responsibility for this policy

The Company Directors have overall responsibility for ensuring this policy with senior management; and managers have day to day responsibility to ensure compliance with our legal and ethical obligations. The Operations Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

Compliance with this policy

You must ensure that you read, understand, and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.

You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify the HR Manager or the Operations Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify us, or you may report it in accordance with our Whistleblowing Policy as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with HR or the Operations Manager. 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.

The Company is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the HR Manager or Operations Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedure.

Communication and awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Our Supply Chains

Our supply chains include the sourcing of raw materials principally related to manufacturing of medical/healthcare apparel and surgical drapes. Our anti-slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk –


•Where possible we build long standing relationships with all our suppliers and make clear our expectations of business behaviour

•With regards to national or international supply chains, our point of contact is preferably with a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes.

•We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.

Supplier adherence to our Values

We have a zero-tolerance approach to Slavery and Human Trafficking. We expect all those in our supply chain and contractors to comply with our values. The Directors have been briefed on the subject and it is discussed in management meetings to raise awareness and reviewed annually

Areas of Risk in Supply Chain

All global supply chains carry an element of risk. We have identified some areas of our supply chain operations to be at higher risk of Modern Slavery and/or Human Trafficking type practices.

Using the Global Slavery Index we have identified South East Asia and Turkey as potentially higher risk. When engaging with suppliers in these regions our Supplier Code of Conduct and MSAT Policies are reviewed with our supply partners to ensure they have understood and committed to work within these polices.

Regular (quarterly) factory visits by our procurement teams as well as our local agents in these countries include official risk assessments as well as unofficial surveillance of working conditions, practices, age of employees etc.

Related Policies

SDS Protection Limited adheres to a number of Corporate Social Responsibility (CSR) Polices which reflect our commitment to the internationally recognised requirements around staff welfare as defined by the International Labour Organisation. Our key policies relating to this are:

Staff Training

To ensure company wide awareness of MSAT all management and staff are updated annually on our goals around MSAT. Our policies are explained during initial employment induction and also form part of the employee’s handbook. This helps all staff to look out for signs of modern slavery and the risks involved so they feel empowered to report and alert management. Particular care is taken with our procurement and sourcing teams are kept up to date as they have regular contacts with suppliers in high risk areas.

Our procurement teams are made aware of the potential risk to supply chain staff welfare by taking certain purchasing practices to excess. These include: unrealistic price negotiation, short delivery deadlines, poor stock control.

Due diligence checks are made on prospective new supply partners making use of the Responsible Sourcing Tool

Our effectiveness in combating MSAT

We use the following KPIs to measure how effective we have been to ensure that Slavery and Human Trafficking is not taking place in any part of our business or supply chains:

• Annual reviews in management meetings
•Use of labour monitoring and payroll systems • Communication and personal contact with the supply chain and their understanding of, and compliance with, our expectations.

Using local auditors and company agents we perform regular audits of our supply partners, the audits check the following areas:

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. The Company may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy This statement is made pursuant to 54(1) of the Modern Slavery Act 2015 and constitutes our company’s Slavery and Human Trafficking statement for the current financial year.

This policy does not form part of an employee’s contract of employment and maybe changed at any time to improve its effectiveness or due to new legislation.