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 (SSI) conducts its business and behaves ethically in its interactions with customers, suppliers and employees. SSI upholds basic human rights in its operations. SSI 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. Employees are free to leave at any time.
All employees are expected to act honestly, show respect for others and be trustworthy. SSI accepts the consequences of its decisions.
Training
SSI provides ethics and compliance training to its employees upon joining the company and at intervals afterwards.
Organisation
SSI 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, Israel and Switzerland. They provide SSI variously with components for devices SSI designs and assemble 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
SSI’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
SSI will never knowingly do business with customers, suppliers or others who violate this policy.
Supply chain – Due Diligence – Reporting
SSI 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.
SSI 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 SSI 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, SSI will advise the supplier and ask for a response. If the response is not satisfactory SSI will cease using the supplier and may report the supplier to a relevant authority.
Risk and compliance
SSI 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. SSI has one Chinese supplier which as far as SSI knows after reasonable enquiry is not owned by the Chinese communist party or any of its organs. SSI has no current reason to suspect that any of its suppliers violates basic human rights.
Effectiveness
SSI is a micro business with fewer than 10 employees. SSI’s ability to monitor and influence suppliers many times its size is necessarily limited. In that context SSI believes that the policies and procedures outlined in this statement are proportionate and that by following them SSI 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.
The statement was approved by the board of directors on 20 January 2022.
This statement will be reviewed in January 2023.
Gwilym Davies
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Gwilym Davies, CEO
Stowood Scientific Instruments Ltd
Date: 20 January 2022