Modern Slavery Act

Voluntary Slavery and Human Trafficking Statement for Year Ended 31 December 2023

We oppose slavery and human trafficking in all its forms. This statement sets out the steps we have taken in 2023 to ensure that there is no slavery or human trafficking in our business or in our supply chains, including our policies to prevent slavery and human trafficking, such as Supplier Code of Conduct; implementing supplier contracts that include anti-slavery and human tracking provisions, creating risk assessment and audit plans to mitigate the risk of slavery and human trafficking.

This statement details our commitment to preventing modern slavery from occurring in our business operations and supply chains for the financial year ended 31 December 2023. It has been approved and signed by Helle Egebjerg Kure, Chief Operating Officer, UNOQUIP GmbH.

About us

UNOQUIP is a limited liability company that distributes single-use medical devices in the area of fluid management, urology, airway management, respiratory care, surgical suction, and nursing care under our own brand. Our products are manufactured by third party manufacturers, i.e. our Supply Partners.

Our annual turnover is below £36 million. Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to identify risks and tackle modern slavery and human trafficking in our business and in our supply chains.

Our supply chains are mainly composed of highly specialized partners who are authorised and certified medical device manufacturers in China. We have formal Supply and Quality Agreements in place with them.

Secondly, our logistics service providers operate distribution centres in Belgium, UK, and Australia and are responsible for the shipment of goods to our customers.

Policies

Our Code of Conduct describes our company's commitment to ethical and integrity-driven conduct in all business dealings and with our employees. In particular, the section "Principles for responsible business conduct" underscores our dedication to fair employment practices and the section "Supplier development and partnership" highlights our commitment to preventing slavery and human trafficking in our supply chains.

We also have the following policies in place with respect to modern slavery, which we continuously review and update:

Anti-bribery and Anti-Corruption Policy
Environmental Policy
Equality, Diversity, and Inclusion Policy
Misconduct Policy
Occupational Health and Safety Policy

Due diligence and risk assessment

As part of our compliance with the policies and procedures referred to above and to help identify and monitor the risk of slavery and human trafficking in our supply chain, we are taking the following steps:

We vet suppliers and sub-contractors to ensure that they are committed to ethical labour practices. We include anti-slavery and human trafficking provisions in all our contracts with suppliers. This includes our suppliers providing the following representations, warranties and covenants:

(i) The supplier complies with all applicable laws on working hours and employment rights in the countries in which they operate; (ii) Supplier’s evaluation and treatment of their employees and applicants for employment are free from discrimination and harassment, whether such discrimination or harassment is based on sex, age, race, colour, ancestry, religion, belief, disability, sexual orientation or marital status; (iii) Any products supplied by the supplier to us must be manufactured under conditions in compliance with the principles set out in the International Labour Organisation Eight Fundamental Conventions nos. 29, 87, 98, 100, 105, 111, 138 and 182 and in the United Nations Convention on the Rights of the Child, Article 32; and (iv) No products had been made in whole or in part by sweatshop labour, convict labour or indentured labour under penal sanction.
The supplier has not been convicted of any offence involving slavery and human trafficking and is not and has not been the subject of any investigation, inquiry or enforcement proceedings by any governmental, administrative or regulatory body regarding any offence or alleged offence of or in connection with slavery and human trafficking.
The supplier is responsible for controlling their own supply chain and actively encourages compliance with ethical standards and human rights set out in our Code of Conduct by any upstream supplier of goods and services which is used when performing their obligations under its agreement with us. The supplier will implement, with immediate effect, due diligence procedures for their own suppliers, subcontractors and other participants in the supply chain to ensure that there is no slavery or human trafficking in upstream supply chains.

All our Supply Partners have signed our Supplier Code of Conduct, which includes their commitment for compliance with the following relevant Principles for Responsible Business Conduct:

Forced and Compulsory labour (ILO Conventions Nos. 29 and 105)
Freedom of Association and the Right to Collective Bargaining (ILO Conventions Nos. 87, 98, 135 and 154)
Child Labour (UN Convention on the Rights of the Child, ILO Conventions Nos. 138, 182 and 79, and ILO Recommendation No. 146)
Discrimination Against Women (ILO Conventions Nos. 100 and 111 and the UN Convention on Discrimination)
Harsh or Inhumane Treatment (UN Covenant on Civil and Political Rights, Art. 7)
Health and Safety (ILO Convention No. 155 and ILO Recommendation No. 164)
Wages (ILO Convention No. 131)
Working Hours (ILO Convention No. 1 and 14)
Regular Employment (ILO Convention No. 95, 158, 175, 177 and 181)
Marginalized Populations (UN Covenant on Civil and Political Rights, art. 1 and 2)
Corruption

Together with our Supply Partners we have implemented a 2 years cycle plan for Third Parties, Manufacturers and Partners in order to carry out due diligence and systematically check the performance and the achievement of the agreed and signed policies.

We only employ agency workers through reputable employment agencies that adhere to our anti-slavery and human trafficking policy (or equivalent policies).

In order to mitigate the risk of slavery and human trafficking and to create clarity and transparency about how we monitor the above-mentioned aspects, UNOQUIP has created a risk assessment and audit plan.

Effectiveness in combating slavery and human trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:

The percentage of suppliers and sub-contractors vetted for ethical labour practices.
The number of inspections of direct suppliers and sub-contractors in our supply chains in the past year.
The number of reported breaches in the past year.
Percentage of staff receiving training on identifying and addressing the risk of slavery and human trafficking in our business and supply chains.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. We also require our business partners to provide training to their staff and suppliers and providers.

Further steps

Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:

Evaluating risks in supply chains, including supply partners engaging contract manufacturers and sourcing of raw materials, and third party aiding cross-border processes (e.g., customs brokers, freight forwarders), addressing potential issues.
Conducting partner due diligence post-risk assessment and enforcing consequences as and when red flags are identified.
Planning to mitigate risks of slavery and human trafficking in our supply chains by reviewing partners' controls, seeking confirmation of adherence to our standards, and conducting suitable checks, including audits, where necessary.

Helle Egebjerg Kure

Chief Operating Officer, UNOQUIP GmbH

Date: 15.01.2024