Modern Slavery Statement

Purpose of Policy

Kays Medical Ltd strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. The company acknowledges responsibility to adhere to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. 

Scope

As part of Kays Medical’s due diligence process into slavery and human trafficking, the supplier approval process will incorporate a review of the controls undertaken by the prospective supplier. We expect the same high standards from all of our suppliers and business partners of imported goods, including from sources outside the UK and EU. The level of management control required from these suppliers will be continually monitored.  

Kays Medical is a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery: 

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains. 
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy. 
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain. 
• We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risk-based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking. 

Consistent with our risk-based approach we may require: 

• Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct. 
• Suppliers engaging workers through a third party to obtain agreement to adhere to the Code of Conduct from the third party. 
• As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct. 

If we find that other individuals or organisation’s working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach, to terminating such relationship. 

The Company Directors and Senior Management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training etc.) and investment to ensure that slavery and human trafficking is not taking place within the organisation or its associated supply chains.