ANTI SLAVERY POLICY STATEMENT
This statement sets out the steps that Waire Health Limited has undertaken, and is continuing to take, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Waire Health Limited has a zero-tolerance approach to any form of modern slavery. We are committed to acting in an ethical manner, with integrity and transparency in all business dealings.
We are committed to creating effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain and impose those same high standards on our contractors, suppliers and other business partners.
COMPANY STRUCTURE AND SUPPLY CHAINS
Waire Health produces wearable vital signs monitors and supplies healthcare professionals.
As such, Waire Health Limited has an extensive supply chain and we procure goods and services globally. We work with a wide range of different suppliers, subcontractors and partners each of which will have their own subcontractors, affiliates and associate entities. Waire Health Limited therefore is connected to multiple entities through numerous contractual relationships across many countries for instance USA, Canada and mainland Europe.
OUR POLICIES:
We operate a number of internal and external policies to ensure that we are conducting business in an ethical and transparent manner. These include:
Internal Policies:
1. Anti-slavery guidance. Waire Health’s stance on modern slavery, it explains how employees can identify any instances of this and where they can go for help.
2. Procurement Policy which confirms that Waire Health follows government procurement guidance, references modern slavery and the use of RACI outlining roles and responsibilities from tender to contract management.
3. Waire Health Personal Security Policy confirms that eligibility to work in the UK checks are conducted on all employees, including but not limited to checking an original passport, birth certificate or other qualifying documentation.
4. Whistleblowing policy. This ensures all employees know they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
5. Code of good business practice. This code explains the manner in which we behave as an organisation and how we expect our employees to act.
External Policies:
1. Supplier Code of Conduct. Suppliers and their subcontractors must comply with the Supplier's Code of Conduct which includes compliance with the Modern Slavery Act 2015, a prompt payment commitment and ethical behaviour.
DUE DILIGENCE PROCESSES
As part of our initiative to identify and mitigate risk, we:
Operate strict procurement processes, requiring suppliers to comply with all applicable laws and standards, including those which relate to the Modern Slavery Act;
• Base our tender documents on the government standard selection questionnaire (SSQ) with specific questions in the ITT response around the Modern Slavery Act and compliance with it;
• Expect our suppliers to have suitable policies and processes in place within their own businesses to prevent child labour, modern slavery and human trafficking and to cascade those policies to their own suppliers;
• Undertake a continuous review of assurance information from existing suppliers and partners, which includes gathering yearly assurance on modern slavery via contract management meetings and follow up where relevant;
• Request an annual updated response to Modern Slavery Act from our suppliers i.e. policy updates or published statement;
• Have included a specific item relating to the Modern Slavery Act in the agenda of the contract management meetings with suppliers enabling us to be kept informed of and monitor any changes;
• Include appropriate terms in our contractual documentation with suppliers:
o obliging suppliers and their contractors, suppliers and employees to comply with the Modern Slavery Act;
o obliging suppliers and their subcontractors to comply with the Supplier's Code of Conduct;
o reserving the right for us to audit suppliers and their contractors, where we consider it appropriate;
o obliging suppliers to report to us if they are aware of or suspect slavery or human trafficking in a supply chain connected to any Waire Health contracts;
o reserving the right for us to terminate the contract at any time should any instances of modern slavery come to light.
o ensuring prompt payment by Waire Health to suppliers within 30 days of receipt of invoice;
o prohibiting suppliers from sub-contracting without our permission. If sub-contracting is permitted, all duties and obligations from the supply agreement must be included in the sub-contract;
o requiring suppliers to pay its subcontractors within 30 days.
• The Procurement Team follow the advice and guidance in relation to the Modern Slavery Act set out in the Chartered Institute of Purchasing and Supply (CIPS) code of professional conduct.
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.
TRAINING - We regularly conduct modern slavery training for our procurement teams and issue guidance to our employees so that they are aware of the issues surrounding modern slavery and what to do if they suspect that it is taking place
within our supply chain.
OURPERFORMANCEINDICATORS -
• Number of reports in 2018/19 indicating whether modern slavery practices have been identified in Waire Health business or their supply chain: Zero.
• Number of complaints received by Waire Health via its grievance and whistleblowing mechanisms: Zero.
• No recorded instances of modern slavery within Waire Health and/or its supply chain and any related corrective action have been identified in the financial year 2018/19.
APPROVALFOR THIS STATEMENT
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Waire Health Limited's slavery and human trafficking statement for the financial year ending 22/04/2019
This statement was approved by the Board of Directors in April 2019
Waire Health Limited
Signature :
Name : Dave Hurhangee Position : CEO
Date : 4th April 2019