Statement of ethics and against modern slavery and human trafficking
This Statement includes a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 (the Act).
Ethics Policy
Stowood Scientific Instruments Ltd (Stowood) complies with law and regulation in all its operations and takes legal advice when required. Stowood conducts its business and behaves ethically in its interactions with customers, suppliers and employees. Stowood upholds basic human rights in its operations. Stowood does not tolerate the use of human trafficking, modern slavery or child labour in its supply chain and takes proportionate steps to help ensure the same.
All employees are voluntarily employed on contract after interview and the taking up of references. Stowood complies with employment law and regulation. Employees are free to leave or associate at any time.
All employees are expected to act honestly, show respect for others and be trustworthy.
Stowood does not tolerate any corrupt activities.
Stowood accepts the consequences of its decisions.
Training
Stowood provides ethics and compliance training to its employees upon joining the company and at intervals afterwards.
Organisation
Stowood has business operations only in the United Kingdom. It operates in the medical devices sector. Its key suppliers are in the UK, the United States, China and Israel. They provide Stowood variously with components for devices Stowood designs and assembles itself under its own brand, as well as devices, accessories and consumables which it distributes. One US supplier provides software with its devices. Other UK suppliers provide office equipment and a software accounting package.
Policy against Modern Slavery
Stowood’s policy is:
- to support the prevention of slavery and human trafficking
- to comply with the Act in its own operations
- to have zero-tolerance towards slavery and human trafficking in its supply chain
Stowood will never knowingly do business with customers, suppliers or others who violate this policy.
Supply chain – Due Diligence – Reporting
Stowood expects its suppliers to comply with laws and regulations in their jurisdictions and to comply with generally-accepted international ethical standards, which includes producing their goods lawfully, without exploiting the people who make them, and in decent working conditions.
Stowood checks to see if its key suppliers have an anti-slavery or similar policy – many have links to one on their website. If no such policy is evident Stowood will ask them for one or send them a copy of this statement and ask for a reply to confirm compliance.
If an employee suspects illegal or unethical actions by any supplier the employee should report the fact to the CEO or line manager. If verified, Stowood will advise the supplier and ask for a response. If the response is not satisfactory Stowood will cease using the supplier and may report the supplier to a relevant authority.
Risk and compliance
Stowood considers that it operates in a business environment that has a low risk of violations of basic human rights including slavery and human trafficking because with one exception its suppliers are based in the UK, the US and other Western countries where strong and enforceable employment laws exist and human rights are respected. Stowood has one Chinese supplier which as far as Stowood knows after reasonable enquiry is not owned by the Chinese communist party or any of its organs. Stowood has no current reason to suspect that any of its suppliers violates basic human rights.
Effectiveness
Stowood is an SME and therefore its’ ability to monitor and influence suppliers many times its size is necessarily limited. In that context Stowood believes that the policies and procedures outlined in this statement are proportionate and that by following them Stowood supports the prevention of slavery and human trafficking and tries to ensure that its supply chain is free from any such violations of human rights.
Key performance indicators
Staff training
- Target of 95% completion rate for mandatory training modules for eligible staff
Supplier audits
- Complete and review 3 supplier audits as part of ongoing supplier relationship management programme
Supplier modern slavery statement compliance
- Investigate all instances of reported non-compliance
Whistleblowing
Report and investigate 100% of whistleblowing cases made to Stowood.
- Monitor and review the outcomes of whistleblowing cases reported by our partners.
Policies, procedures and governance
Stowood prohibits any threat of violence, harassment and intimidation.
Stowood prohibits the use of worker-paid recruitment fees, compulsory overtime, child labour, discrimination, confiscation of workers original identification documents, and provides access to remedy, compensation and justice for victims of modern slavery. Policies are approved by senior management. Policies are available to workers in your organisation and communicated to them. Policies are available to workers in your supply chain and communicated to them. Relevant staff in our organisation are trained on these policies. High risk suppliers are required to adhere to our modern slavery policies as a contract condition, and trained on the relevant policies. We have assessed how our organisation’s purchasing practices may create pressures on our suppliers that could lead to modern slavery.
During the procurement process our organisation considers modern slavery risks, at Needs identification, Requirement definition, Tender evaluation, Contract award and In-life contract management.
We undertake due diligence to ensure that workers in our supply chains are not trapped in debt bondage as a result of how they were recruited, by including integrated safeguards in to company policies, raised awareness and built capacity of staff to understand risks of debt bondage, screen and evaluate key recruitment agencies/labour providers, monitor key recruitment agencies/labour provider for ethical recruitment and hiring.
Our organisation takes measures to ensure workers in our organisation have access to a grievance mechanism to report incidents or suspected incidences of modern slavery.
We have a Service Level Agreement (SLA) in place for responding to a report of suspected instances of modern slavery – we will react within 72 hours.
We undertake internal audits to assess labour conditions at least every 12 months.
Our training cover’s the ILO’s Forced Labour Indicators:
- Abuse of vulnerability
- Deception
- Restriction of movement
- Isolation
- Physical and sexual violence
- Intimidation and threats
- Retention of identity documents
- Withholding of wages
- Debt bondage
- Abusive working and living conditions
- Excessive overtime
The statement was approved by the board of directors on 02 January 2024.
This statement will be reviewed in January 2025.
Sd. Gwilym Davies
___________________________
Gwilym Davies, CEO
Stowood Scientific Instruments Ltd
Date: 02 January 2024