This is the second annual Modern Slavery Statement to be published by The Binding Site Group Limited pursuant to Section 54 of The Modern Slavery Act 2015. It sets out the actions we have taken to prevent modern slavery and human trafficking in our business and supply chain, for the financial year ended 30 September 2017.
About us and our Supply Chain
The Binding Site is an international manufacturer and supplier of specialist, regulated, medical diagnostic products which improve the diagnosis and management of blood cancers and immune system disorders. We source the majority of our goods and services, including the raw materials and components for our products, through a centralised UK based purchasing team, primarily from countries based in Europe and the USA. Production takes place in both the USA and at our UK head office. We supply our products directly, via our subsidiaries and branches in Europe and the USA and through our worldwide network of distributors.
We strongly believe in fair working practices and we have zero tolerance of slavery and human trafficking. This principle is enshrined in our Code of Business Conduct which every employee of The Binding Site and its group companies must adhere to and which is published on our internal intranet and external website. In addition, via our Whistleblowing Policy we encourage our employees to report concerns relating to slavery and human trafficking without fear of recrimination.
Due Diligence and Assessment of Risk
Our key suppliers (assessed according to criticality, risk and value) undergo regular quality audits (which may include physical inspections) and before appointment our distributors are always subject to full due diligence. Both processes are documented and contain specific questions to assist in the identification of potential slavery and human trafficking.
Prior to trading, all new suppliers to the UK business must commit in writing to the principles enshrined in our Code of Business Conduct to ensure that we only trade with suppliers whose values are akin to our own. This is reinforced on each purchase order we raise.
Specific checks are in place to identify any suppliers based in countries considered to be high risk on the Global Slavery Index. Since 2017 any new supplier based in or controlled from a high risk country must be approved at board level before orders can be placed.
Through our contracting process with our suppliers, distributors and customers we promote compliance with the Modern Slavery Act both in form and spirit.
During the financial year ending 2017 we launched a new set of terms and conditions of purchase specifically requiring compliance with the Modern Slavery Act 2015.
Internally we verify the identity and right to work of every employee by inspecting original passports and visas to ensure that there are no potentially vulnerable employees. We only use agencies that have been verified through our internal due diligence processes.
Any concerns arising from the above processes are escalated to senior level.
Our Corporate Compliance Training Programme provides appropriate corporate compliance training. During the financial year ending 2017 all senior managers in the UK, as well as relevant employees in functions such as HR, Purchasing, Commercial and Distribution received dedicated training to assist them to identify potential slavery and human trafficking and how to report it.
All new employees and consultants commit to our Code of Business Conduct during their induction process.
The Binding Site’s Chief Financial Officer is ultimately responsible for ensuring the effectiveness of and the Group’s compliance with all policies, procedures and training requirements set out in this statement. This includes an annual review with the Board to ensure our continual improvement and commitment in this key area of our Code of Business Conduct.
This statement has been approved by the Board of The Binding Site Group Limited.
Chief Financial Officer
22 March 2018