HM Medical Distribution LTD Anti-Modern Day Slavery Policy
    What is moderns slavery ?

  The Modern Slavery Act (MSA) 2015 covers four activities:
Slavery : Exercising powers of ownership over a person
Servitude : The obligation to provide services is imposed by the use of coercion
Human trafficking: Arranging or facilitating the travel of another person with a view to their exploitation
Forced or compulsory labour:  Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
This policy covers all four activities.


  How Is It Relevant to Us?
 
  1. Modern slavery is a complex and multi-faceted crime and tackling it requires many organisations and individuals to play a part. At first glance, individuals may think this subject is irrelevant to us, but it’s not.
  2. At a very basic level, of course preventing exploitation and human trafficking, and protecting our staff and reputation makes good business sense.
  3. The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do more.
  4. With this in mind, we need to pay particularly close attention to our manufacturer and supply chain, especially if identified areas which have historically proven to be at risk of the activities:
  • Outsourced activities such collaborating and consultancy work in relation to products that we market and sell, etc
  • Short term hire of low skilled labour by our manufacturer in production of the products we represent and sell to the UK markets .
  • Sourcing of raw materials used by our manufacturer that we represent our products for distribution from certain locations in the world.
 

Responsibilities
 
  1. The Company, our Director and our collaborating colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.
  2. Everyone must observe this Policy and be aware that ‘turning a blind eye’ is unacceptable and simply not an option.


  HM Medical Distribution LTD   We will:
  1. Maintain clear policies and procedures preventing exploitation and human trafficking, and protecting our workforce and reputation.
  2. Be clear about our recruitment line Equality and Diversity Policy.
  3. Examine our supply chains and be clear with key clients about our expectations regarding the Act.
  4. Lead by example by making appropriate checks on all possible employees, recruitment agencies, suppliers, etc to ensure we know who is working for us.
  5. Ensure we have in place an open and transparent grievance process for all staff.
  6. Seek to raise awareness so that our collaborating colleagues know what we are doing to promote their welfare.
  7. Make a clear statement that we take our responsibilities to our employees and our clients seriously (see Anti-slavery statement).
    Director   Director will:
  1. Listen and be approachable to colleagues.
  2. Respond appropriately if they are told something that might indicate a colleague is in an exploitative situation.
  3. Remain alert to indicators of slavery.
  4. Raise the awareness and ensure all potential employees are provided a copy of this policy and be aware of their responsibilities.
  5. Use their experience and professional judgement to gauge situations.
   Collaborating Colleagues   We all have responsibilities under this policy. Whatever your role or level of seniority, you must:
  1. If you suspect someone (a colleague or someone in our manufacturing or supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure.
  2. Follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated.
  3. Tell us if you think there is more we can do to prevent people from being exploited.
    The Potential Risks   The principal potential areas of risk we may face, related to slavery and human trafficking, include:
  1. To identify areas of the supply chain as being at a higher risk.
  2. Recruitment either through agencies or direct.
  3. Ensuring all suppliers deemed “at risk” are fully supportive to the aims of this policy, (including asking for copies of their Anti Modern Slavery Statement and Policies).
  4. Any procurement, selling and supplying protocols which are already mutually inclusive of the aims of this policy into the due diligence.
  5. If any issues are identified then this is escalated to the Director and collaborating consultancy covering sales and marketing purposes for the business, with all methods of remediation to be available (up to and including exiting the relationship with the manufacturer and supplier).
  Recruitment   Using Agencies The Company follows firm policy and only uses agreed specified reputable recruitment agencies if required. We expect all recruitment agencies with whom we engage:
  1. To fully comply with the Modern Anti-Slavery Act 2015.
  2. Are free from ethical ambiguities.
  3. Are transparent, accountable and auditable.
    General Recruitment  
  1. We always ensure all staff have a written contract of employment.
  2. We always ensure staff are legally able to work in the UK.
  3. We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
  4. If, through our recruitment process, we suspect someone is being exploited, the Director will be informed and will follow our reporting procedures.
  Identifying Slavery   There is no typical victim and in some situations victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a slavery or trafficking victim:
  1. The person is not in possession of their own passport, identification or travel documents.
  2. The person is acting as though they are being instructed or coached by someone else.
  3. They allow others to speak for them when spoken to directly.
  4. They are dropped off and collected from work.
  5. The person is withdrawn or they appear frightened.
  6. The person does not seem to be able to contact friends or family freely.
  7. The person has limited social interaction or contact with people outside their immediate environment.
This list is not exhaustive.   Remember, a person may display a number of the trafficking indicators set out above but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right. If you have a suspicion, report it to the HR Department who will follow our reporting procedures.   Reporting Slavery
  1. Talking to someone about your concerns may stop someone else from being exploited or abused.
  2. If you think that someone is in immediate danger, dial 999.
  3. Otherwise, you should discuss your concerns with the company Director who will decide a course of action which may include contacting the Police or appropriate Government Organisation.
  4. Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with the Company Director before taking any further action.
  We ensure that all employees are made aware of this policy, and their obligation at their point of employment though Mandatory Training Procedure.   We will review our Anti-slavery policy regularly.
Anti-slavery policy statement
HM Medical Distribution LTD has a zero-tolerance approach to slavery and is committed to preventing acts of slavery and human trafficking from occurring within both its business and supply chain, and imposes those same high standards on its manufacturing contractors, suppliers and other business partners.


  Company structure

  HM Medical Distribution LTD is a small business  within the first year of performance , distributor of medical orthopaedic casts and splints and organises all related services in collaborations with logistics providers to ensure safe and appropriate product delivery to the clients organisations.


  Predominately HM Medical Distribution LTD aim to supply  NHS Hospitals and Private Health Care Organisations


  HM Medical Distribution LTD operates from an office in Ashton-in-Makerfield, Wigan, WN4 9AN


  Due diligence processes

  We:
  • Operate strict procurement processes, ensuring our distribution comply with all applicable laws and standards, including those which relate to the Modern Slavery Act;
  • Expect our manufactures client that we represent to UK markets  to have suitable anti-slavery and human trafficking policies and processes in place within their own businesses and to cascade those policies to their own suppliers;
  • Have completed an analysis of assurance information from existing suppliers and partners and followed up where relevant;
  • Source manufacturers goods from only approved and affiliated sources;
  • Regularly review our policy and effectiveness of meeting the objectives of this policy;
  • Have added a specific item relating to the Modern Slavery Act to the agenda of the contract management meetings with manufacturers and suppliers enabling us to be kept informed of any changes.
 

The above procedures are designed to:
  • Identify and assess potential risk areas in our business and supply chains.
  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
  • Monitor potential risk areas in our business and supply chains.
  • Provide adequate protection for whistle blowers.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes HM Medical Distribution LTD slavery and human trafficking statement for the financial year ending .....


  HM Medical Distribution LTD  

  Date: 25 November 2019
Equality and Diversity Policy
HM Cast Medical Distribution LTD is dedicated to encouraging a supportive and inclusive culture amongst the staff , clients and it is within our best interest to promote diversity and eliminate discrimination in the work environment.

Our aim is to ensure that all employees and job applicants are given equal opportunity and that our organisation is representative of all sections of society.


  This policy support our commitment to provide equality and fair process to all aspects of the business and provide favourable facilities or treatment on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, ethnic origin, colour, nationality, national origin, religion or belief, or sex and sexual orientation.

We are against  to all forms of unlawful and unfair discrimination.

  All employees, no matter whether they are part-time, full-time, or temporary, will be treated fairly and with respect.

All employees will be given help and encouragement to develop their full potential and utilise their skills and  talents.

Therefore, the skills and resources of our organisation will be fully utilised and we will maximise the efficiency of our staff members and collaborating contractors.

  HM Medical Distribution LTD   will commit to the following :
  • To create an environment in which individual differences and the contributions of all team members are recognised and valued.
  • To create a working environment that promotes dignity and respect for every employee.
  • To not tolerate any form of intimidation, bullying, or harassment, and to discipline those that breach this policy.
  • To provide training, development, and progression opportunities available to all staff.
  • To promote equality in the workplace, which HM Medical Distribution LTD believes is good management practice .
  • To encourage anyone who feels they have been subject to discrimination to raise their concerns so we can apply appropriate measures.
  • To encourage employees to treat everyone with dignity and respect.
  • To regularly review all our employment practices and procedures so that fairness is maintained at all times.
 

HM Medical Distribution LTD will inform all employees that an equality and diversity policy is in operation and that they are obligated to comply with its requirements and promote fairness in the workplace. The policy will also be drawn to the attention of funding agencies, stakeholders, customers, learners, and job applicants.  

HM Medical Distribution LTD  equality and diversity policy is fully supported by management and in compliance with standards and requirements  .  

Monitoring and review
This policy will be reviewed annually and incorporate the following : Changes in legislation Good practice models Feedback from clients and staff Concerns and complaints raised by clients and staff

  A plan for implementing any changes will be developed in consultation with Director Ionut Mircea and collaborating staff.

HM Medical Distribution LTD has the overall responsibility for the effective operation of this policy, the responsibility for communicating this policy to the relevant manufacturing clients , collaborating staff and supplying clients for the purpose of investigating any concerns or complaints under this policy.

  HM Medical Distribution LTD

  Date:  24 November 2019
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