Modern Slavery Policy

Phoenix Medical is committed to ensuring that modern slavery and human trafficking are not taking place within our business operations or supply chains. This policy sets out our approach in line with the Modern Slavery Act 2015.

Integrity

We operate with ethical standards and lawful conduct.

Due diligence

We assess suppliers, review risk, and set clear expectations in contracts.

Speak up

We offer confidential reporting and protect whistleblowers from retaliation.

Policy sections

1. Introduction

Phoenix Medical is committed to ensuring that modern slavery and human trafficking are not taking place within our business operations or supply chains.

2. Purpose

Ensure employees, suppliers, and stakeholders understand our commitment to preventing modern slavery.
Outline steps to identify, mitigate, and address risks.
Encourage transparency within operations and supply chains.

3. Scope

This policy applies to all employees, contractors, suppliers, and any other parties working with or on behalf of Phoenix Medical.

4. Our commitment

Operating with integrity and ethical standards.
Complying with applicable laws and regulations regarding modern slavery and human trafficking.
Identifying and assessing potential risks in supply chains and business operations.
Taking appropriate action if modern slavery is identified, including reporting to relevant authorities.
Improving practices to combat modern slavery.

5. Supply chain due diligence

Supplier assessments: regular assessments to support compliance with the Modern Slavery Act 2015.
Risk analysis: identifying vulnerable areas and implementing measures to reduce risk.
Supplier contracts: obligations to comply with our anti-slavery expectations and applicable laws.

6. Supplier conduct

When dealing with suppliers, we avoid:

Aggressive pricing that does not consider production costs.
Short lead times.
Late high-volume orders.
Inaccurate forecasting.
Late or extended payments.
Late withdrawal from contracts.
Issuing unfair penalties.
Supplying inaccurate technical specifications.

7. Training and awareness

Providing regular training on modern slavery and human trafficking.
Helping employees understand indicators and how to report concerns.
Engaging suppliers and partners to promote awareness of modern slavery risk.

8. Reporting and whistleblowing

Phoenix Medical encourages all employees, suppliers, and stakeholders to report concerns. We will:

Provide a confidential and secure whistleblowing mechanism.
Investigate reports promptly and treat them confidentially.
Protect whistleblowers from retaliation.

9. Governance and accountability

Management holds overall responsibility for compliance with this policy, including:

Appointing a Modern Slavery Compliance Officer to oversee implementation.
Reviewing the policy annually and updating it where required.

10. Monitoring and review

Regularly monitor and audit supply chains to support compliance.
Review and update the policy to reflect changes in law or company operations.
Report progress in our annual Modern Slavery Statement.

11. Conclusion and approval

Phoenix Medical is dedicated to playing its part in the global fight against modern slavery. We expect all employees, suppliers, and partners to share this commitment and participate in preventing and addressing modern slavery.

Approval & implementation: Approved by the Managing Director and effective from 05/02/2024. Reviewed and updated annually or as required.

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Modern Slavery Policy | Ethical Sourcing & Supply Chain Commitment UK | Phoenix Medical

Modern Slavery Policy

Integrity

Due diligence

Speak up

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