Modern Slavery Policy

Modern slavery and human trafficking statement

Introduction

Footlabs is committed to a zero-tolerance approach to modern slavery and human trafficking. This Modern Slavery and Human Trafficking Statement is made in compliance with section 54(1), Part 6 of the Modern Slavery Act 2015 and outlines our actions and activities for the financial year ending 31st of October 2023.

Modern slavery is a crime and a violation of fundamental human rights. It encompasses various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty for personal or commercial gain. At Footlabs, we are dedicated to acting ethically and with integrity in all our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere within our own business or in any of our supply chains.

This statement serves to ensure transparency in our business operations and our approach to tackling modern slavery throughout our supply chains, in line with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We also expect our suppliers to hold their own suppliers to the same high standards.

This statement applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

Our Business and Supply Chains

Footlabs is a leading provider in the medical industry, specialising in the design, manufacture, distribution, and repair of custom-made orthotic devices. Our core business activities are centred around delivering high-quality, bespoke orthotic solutions that enhance the mobility and well-being of our clients.

Our supply chain is structured to support our commitment to excellence and ethical practices. We source materials and components from a network of trusted suppliers, ensuring that each link in our supply chain adheres to our stringent standards. Our key suppliers are primarily based in countries identified as low-risk for modern slavery by the Global Slavery Index. This strategic choice helps us maintain a supply chain that is not only efficient but also aligned with our ethical values.

Footlabs is unwavering in its commitment to engaging only with suppliers who respect human rights. We have implemented rigorous vetting processes to ensure that all our suppliers comply with the Modern Slavery Act 2015. This includes contractual obligations that explicitly prohibit the use of forced, compulsory, or trafficked labour. We expect our suppliers to uphold these standards and to extend the same expectations to their own supply chains.

By maintaining transparency and integrity in our business dealings, we strive to create a supply chain that is free from modern slavery and human trafficking. Our dedication to ethical practices is a cornerstone of our operations, reflecting our broader commitment to social responsibility and human rights.

Our Policies on Modern Slavery and Human Trafficking

At Footlabs, we are unwavering in our commitment to combat modern slavery and human trafficking in all its forms. Our Modern Slavery and Human Trafficking Policy is designed to ensure that our business operations and supply chains are free from any form of slavery, servitude, forced or compulsory labour, and human trafficking.

Ethical Practices and Standards

We uphold the highest ethical standards and expect the same from our employees, suppliers, and business partners. Our policy mandates that all individuals working for or on behalf of Footlabs, including employees, contractors, and third-party representatives, adhere to these standards. We have integrated specific prohibitions against the use of forced, compulsory, or trafficked labour into our contracting processes. This ensures that our suppliers and their supply chains are also committed to these high standards.

Reporting and Addressing Concerns

To foster a transparent and ethical working environment, we have established robust mechanisms for reporting and addressing concerns related to modern slavery. Employees and stakeholders are encouraged to report any suspicions or evidence of modern slavery without fear of recrimination. Reports can be made directly to any member of the Board or through designated reporting channels outlined in our employee staff handbook. We take all reports seriously and will investigate and address any concerns promptly and effectively.

Our policy is not just a statement of intent but a practical framework that guides our actions and decisions. By embedding these principles into our daily operations, we aim to ensure that modern slavery and human trafficking have no place in our business or supply chains.

Risk Assessment and Management

At Footlabs, we recognise the critical importance of identifying and mitigating the risks of modern slavery within our business operations and supply chains. Our approach to risk assessment and management is comprehensive, systematic, and continuously evolving to address emerging threats and ensure compliance with the Modern Slavery Act 2015.

Identification of High-Risk Areas

We have undertaken a thorough review of our business and supply chains to identify areas at high risk of modern slavery. This includes:

Geographical Risk: We assess the countries where our suppliers operate, focusing on those with higher incidences of modern slavery as indicated by the Global Slavery Index. Currently, 100% of our suppliers are based in the lowest risk countries.
Sectoral Risk: We evaluate the specific sectors within our supply chain that may be more susceptible to modern slavery, such as raw material sourcing and manufacturing processes.
Operational Risk: We scrutinise our internal operations, including recruitment and employment practices, to ensure no part of our business is vulnerable to modern slavery.

Processes for Assessing and Mitigating Risks

To effectively manage these risks, we have implemented robust processes, including:

Supplier Due Diligence: We conduct rigorous due diligence on all new and existing suppliers, requiring them to adhere to our strict anti-slavery policies. This includes contractual obligations prohibiting the use of forced, compulsory, or trafficked labour.
Audits and Assessments: Regular audits and assessments of our supply chain are conducted to ensure compliance with our standards. We engage third-party auditors where necessary to provide an unbiased evaluation.
Employee Training: Our managers and HR professionals undergo mandatory training on recognising and addressing modern slavery. This training is also integrated into our employee induction programme to ensure awareness at all levels.

Regular Review and Update of Risk Management Strategies

We are committed to the continuous improvement of our risk management strategies. This involves:

Annual Reviews: We conduct annual reviews of our risk assessment processes to identify any new risks and update our mitigation strategies accordingly.
Stakeholder Engagement: We actively engage with stakeholders, including employees, suppliers, and industry bodies, to stay informed about best practices and emerging risks.
Policy Updates: Our policies on modern slavery and human trafficking are regularly reviewed and updated to reflect the latest legal requirements and industry standards.

By maintaining a proactive and vigilant approach to risk assessment and management, Footlabs ensures that we uphold our commitment to ethical business practices and the eradication of modern slavery in all its forms.

Due Diligence Processes

At Footlabs, we are committed to ensuring that our supply chains are free from modern slavery and human trafficking. To achieve this, we have implemented a comprehensive due diligence process that includes several key steps:

Steps Taken to Ensure Due Diligence

1. SupplierVettingandAuditProcesses:Weconductthoroughvettingofall potential suppliers before entering into any business relationship. This includes evaluating their policies and practices related to human rights and modern slavery. We also perform regular audits of our existing suppliers to ensure ongoing compliance with our standards. These audits are both announced and unannounced, allowing us to gain a true picture of our suppliers’ operations.

2. RiskAssessment:Wecontinuouslyassesstheriskofmodernslaverywithinour supply chains. This involves identifying high-risk areas and implementing targeted measures to mitigate these risks. Our risk assessment process is dynamic and is reviewed regularly to adapt to any changes in our supply chain or operating environment.

Collaboration with External Partners and Stakeholders

We recognise that combating modern slavery requires a collaborative approach. Therefore, we actively engage with external partners and stakeholders to enhance our due diligence processes:

1. IndustryCollaboration:Weparticipateinindustryforumsandworkinggroups focused on eradicating modern slavery. This allows us to stay informed about best practices and emerging risks, and to contribute to collective efforts to address this issue.

2. SupplierEngagement:Wemaintainopenlinesofcommunicationwithour suppliers, encouraging them to share their own challenges and successes in combating modern slavery. This collaborative approach helps us to build stronger, more transparent relationships and to support our suppliers in improving their practices.

By implementing these due diligence processes, Footlabs aims to ensure that our supply chains are ethical and free from modern slavery. We are committed to continuous improvement and will regularly review and enhance our due diligence measures to uphold the highest standards of integrity and human rights.

Training and Awareness

At Footlabs, we recognise the critical role that training and awareness play in combating modern slavery and human trafficking. To this end, we have implemented comprehensive training programs and ongoing awareness initiatives to ensure that all employees are equipped with the knowledge and tools necessary to identify and address potential instances of modern slavery.

Mandatory Training Programs

We have established mandatory training programs specifically designed for our managers and HR professionals. These programs focus on recognising the signs of modern slavery and human trafficking, understanding the legal and ethical implications, and knowing the appropriate steps to take if such issues are suspected. The training covers:

Definitions and forms of modern slavery.
Indicators of slavery and human trafficking.
Procedures for reporting and addressing concerns.
Resources and external support available.

Ongoing Awareness Campaigns

In addition to targeted training for key personnel, we conduct ongoing awareness campaigns for all employees. These campaigns are designed to foster a culture of vigilance and responsibility throughout the organisation. Key elements of our awareness initiatives include:

Regular updates and reminders about modern slavery issues via internal communications.
Inclusion of modern slavery information in our employee induction programme.
Workshops and seminars to reinforce understanding and engagement.

Resources and Support

We are committed to providing our employees with the resources and support they need to report any concerns related to modern slavery. Our support mechanisms include:

A confidential reporting system that allows employees to raise concerns anonymously.
Access to a dedicated helpline for advice and support.
Clear guidance on the steps to take if modern slavery is suspected, ensuring that employees can act without fear of recrimination.

By investing in training and awareness, Footlabs aims to create an informed and proactive workforce that is capable of identifying and addressing modern slavery risks, thereby upholding our commitment to ethical business practices and human rights.

Performance Indicators

To ensure the effectiveness of our efforts in preventing modern slavery, we have established a comprehensive set of performance indicators. These metrics are designed to provide clear insights into our progress and highlight areas for continuous improvement.

Metrics Used to Measure Effectiveness

We utilise a variety of metrics to gauge the success of our modern slavery prevention initiatives. These include:

Supplier Audits: The number and frequency of audits conducted on our suppliers to ensure compliance with our modern slavery policies.
Training Completion Rates: The percentage of employees, managers, and HR professionals who have completed modern slavery awareness and recognition training.
Incident Reports: The number of reported incidents related to modern slavery and the actions taken in response.
Supplier Compliance Rates: The percentage of suppliers who have signed our code of conduct and demonstrated adherence to our anti-slavery standards.

Regular Monitoring and Reporting

We are committed to the regular monitoring and reporting of these key performance indicators. This involves:

Quarterly Reviews: Conducting quarterly reviews of our performance data to identify trends and areas requiring attention.
Annual Reports: Publishing an annual report summarising our performance against these indicators, which is reviewed by the board of directors.
Stakeholder Feedback: Gathering feedback from stakeholders, including employees, suppliers, and customers, to ensure our approach remains effective and relevant.

Continuous Improvement Initiatives

Based on the performance data collected, we undertake continuous improvement initiatives to enhance our modern slavery prevention efforts. These initiatives include:

Policy Updates: Regularly updating our policies and procedures to reflect best practices and emerging risks.
Enhanced Training Programs: Developing and implementing advanced training modules to deepen the understanding and capabilities of our staff in identifying and preventing modern slavery.
Supplier Engagement: Strengthening our engagement with suppliers through workshops, seminars, and collaborative projects aimed at promoting ethical practices throughout the supply chain.

By rigorously monitoring our performance and committing to continuous improvement, we strive to uphold the highest standards in combating modern slavery and human trafficking within our business and supply chains.

Our Commitment

At Footlabs, we reaffirm our unwavering commitment to upholding ethical business practices and eradicating modern slavery in all its forms. We recognise that modern slavery is a grave violation of human rights, and we are dedicated to ensuring that our business operations and supply chains are free from any form of forced labour, servitude, or human trafficking.

Long-Term Goals

Our long-term goals are centred on the complete eradication of modern slavery within our business and supply chain. We aim to:

Continuously enhance our due diligence processes to identify and mitigate risks of modern slavery.
Foster a culture of transparency and accountability across all levels of our organisation.
Strengthen our partnerships with suppliers to ensure they adhere to the highest ethical standards.
Regularly review and update our policies and procedures to reflect best practices in combating modern slavery.

Industry Initiatives and Partnerships

We understand that combating modern slavery requires a collaborative effort. Therefore, we actively engage with industry initiatives and form strategic partnerships to amplify our impact. By working together with other businesses, non-governmental organisations, and governmental bodies, we aim to:

Share knowledge and best practices to improve our collective response to modern slavery.
Participate in industry forums and working groups dedicated to eradicating modern slavery.
Support initiatives that promote human rights and ethical labour practices globally.

Our commitment to ethical business practices is not just a legal obligation but a moral imperative. We will continue to take proactive steps to ensure that modern slavery has no place in our business or supply chains, and we will hold ourselves and our partners to the highest standards of integrity and respect for human rights.

Approval and Review

This Modern Slavery Statement has been reviewed and approved by the board of directors of [Your Company Name]. The board is committed to ensuring that our approach to tackling modern slavery and human trafficking remains robust and effective.

The statement will be reviewed and updated annually to reflect any changes in legislation, our business operations, or our supply chains. This ensures that our policies and practices continue to meet the highest standards and effectively address the risks of modern slavery.

For further inquiries or concerns regarding this statement or our efforts to combat modern slavery, please contact us at:

Danny Revill – Compliance Director

Date of Approval: 1st November 2023
Next Review Date: 1st November 2024