Under the Modern Slavery Act 2015, Chapter 30, it is an offence to:
- hold a person in slavery, servitude and forced or compulsory labour, as defined by Article 4
of the Human Rights Convention,
- provide work or services that result in exploitation of a person, or to
- arrange or facilitate travel by recruiting, transporting or transferring, harbouring or
receiving, or transferring or exchanging control over a person for the purpose of exploitation.
Ideal Medical International Limited have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. We are committed 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.
We are 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 prohibit the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect the same standards from our contractors, suppliers, business partners.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels and business partners.
This policy does not form part of any employee's contract of employment and we may amend it at any time.
Responsibility for the Policy
The Chief Executive Officer has overall responsibility for ensuring this policy complies with our legal
and ethical obligations, and that all those under our control comply with it.Our Head of Quality & Regulatory 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. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Business Compliance Officer.
Compliance with the 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 your manager or the Head of Quality & Regulatory 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 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 your manager or 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 our supply chains constitutes any of the various forms of modern slavery,
raise it with your manager or Business Compliance Officer.
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. We are 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 Chief Executive Officer immediately. If the matter is not remedied,
and you are an employee, you should raise it formally using our 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, forms part of the induction process for all individuals who work for us, and regular training 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.
Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Policy made effective 18th October 2021, a signed hardcopy is retained at Ideal Medical International
Limited, Unit B, Blenheim House, 1 Blenheim Road, Longmead Industrial Estate, Epsom, KT19 9AP.