Sterimed Medical Implants UK Ltd is opposed to all forms of exploitation, including slavery, human trafficking, and the use of child or forced labour. We are committed to making meaningful improvements to sustainable workplace conditions and business practices, including, but not limited to, the prevention of forced or trafficked labour. We do not employ children before they have reached the legal age to have completed their compulsory education, as defined by the relevant authorities.
This statement is made in response to section 54 (1) part 6 of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.
Modern slavery is an umbrella term that covers human trafficking, slavery, servitude, and forced labour. Child labour, as defined by the International Labour Organisation (ILO) Convention, is “Work by children under the age of 12; Work by children under the age of 15 that prevents school attendance; and work by children under the age of 18 that is hazardous to the physical or mental health of the child”.
Sterimed Medical Implants UK Ltd is an equal opportunities employer, committed to ensuring an inclusive, non-discriminatory, ethical working environment for our staff.
We do not, and will not, enter into business with any organisation, in the UK or abroad, which knowingly supports or is involved in slavery, servitude, and forced or compulsory labour.
Supply Chain
We procure goods and services from a restricted range of UK and overseas suppliers. We do not tolerate or condone the use of modern slavery, child labour, forced labour, or human trafficking within our organisation or supply chain, with a zero-tolerance approach.
Our suppliers and subcontractors are an important part of our success and culture; we expect each partner to conduct their business activities with the same commitment to ethical business practices as ourselves. Prior to any relationship agreement, we carry out extensive due diligence whereby compliance with our expectations must be demonstrated and committed to. Details of all subcontractors and suppliers can be provided, as well as due diligence findings and vetting forms. We (or our supply chain):
- Will not use forced or compulsory labour
- Will ensure that terms of employment are voluntary
- Will not hold passports of migrant workers
- Will comply with the minimum age requirements prescribed by applicable laws
- Will compensate workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay agreements
- Will abide by applicable law concerning the maximum hours of labour – such as the provisions of the Working time Directive or other applicable laws
- Will keep records of and be entirely transparent in complying with the above.
Any supply chain partner who is found to engage in modern slavery or human trafficking will have their supply agreements terminated immediately. If any supply chain partner is found to be in violation of our policy statements or agreements, we will take prompt remedial measures to address the violation, including but not limited to termination of the business relationship and involvement of legal authority(s).
Policies relating to the Modern Slavery Act 2015
The following policies are available to all staff:
- Code of conduct
- Equality, Diversity, and Inclusion Policy
- Grievance Policy
- Safeguarding Children and Vulnerable Adults Policy
- Whistleblowing Policy
- Bullying and Harassment Policy
- Recruitment Policy and Toolkit
- Procurement and Ethical Sourcing Policies
- Corporate Social Responsibility and Social Value Policy
Embedding the Principles
We will continue to embed the principles through:
- Ensuring staff are aware of the Modern Slavery Act 2015 and providing information regarding the appropriate action to take if they suspect a case of slavery, human trafficking, and forced child labour.
- Ensuring staff involved with procurement are aware of, and follow gov.uk Procurement Policy Note 05/19: Tackling Modern Slavery in Government Supply Chains – GOV.UK (www.gov.uk)
- Following our values-based, safer recruitment procedure
- Complying with child labour laws, including those related to wages, hours worked, overtime, and working conditions.
In the next year we will:
- Continue to take action to embed a zero-tolerance approach towards modern slavery, human trafficking, and forced child labour.
- Ensure staff know initial steps to take should slavery or forced child labour be suspected.
- Audit annually.
- Undertake due diligence when considering new suppliers and review existing suppliers.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Managing Director endorses this policy statement and is fully committed to its implementation.
Signed: S. Raad
Name: Sleiman Raad
Position: Managing Director
Date: 10th January 2024
Review Due: 10th January 2025
Employee Information links:
- eti_base_code_guidance_modern_slavery_web.pdf (ethicaltrade.org)
- Modern Slavery Act 2015 (legislation.gov.uk)
- Protecting children from trafficking and modern slavery | NSPCC Learning
- Child Labour Prevention & Remediation – The Centre for Child Rights and Business (childrightsbusiness.org)
- Reporting suspected modern slavery or forced child labour as a member of the public
- If an emergency situation, call the police (999)
- Online: File a report (modernslaveryhelpline.org) Modern Slavery Helpline: 0800 0121 700
