Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common, the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited.
Future Medical strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to implement systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
Future Medical Equipment Ltd, as part of the Elite Medical Group, has a zero-tolerance approach to Modern Slavery. We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all of our suppliers and other business partners, and 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, and we expect that our suppliers hold their own suppliers to the same high standards.
This policy applies to all persons working for Future Medical 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. This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Responsibility for the Policy
Future Medical’s Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
Future Medical’s Compliance Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and for internal control systems and procedures, ensuring they are effective in countering modern slavery.
All Future Medical Employees are responsible for complying with the requirements of the policy as a direct requirement of the Modern Slavery Act 2015.
Complying with the Policy
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains. Future Medical Employees are encouraged to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Compliance Manager.
All Employees must read, understand and comply with the policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your Line Manager or the Compliance Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
Suspecting/Reporting a Breach of Policy
If you believe or suspect a breach of this policy or have any reason to believe that a breach may occur, you must speak to your Line Manager or the Compliance Manager. Additionally, if you are unsure about whether a particular act, the treatment of workers more generally or their working conditions within any tier or supply chain constitutes any of the various forms of modern slavery, again please speak with your Line Manager or the Compliance Manager. If you are not satisfied that your concern has been acted upon in an appropriate manner, you can in confidence approach any member of the Board.
Future Medical aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
Future Medical is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. The definition of detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
If you believe that you have suffered any such treatment, you should inform the Compliance Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the Future Medical’s Staff Handbook section 10 pages 30 to 33.
Communication and Awareness of the Policy
Training on the policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Breach of the Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Future Medical will review its policies and procedures periodically to reflect changes in legislation and good practice. Policies in place to support the Human Trafficking and Slavery Policy are:
- Equality and Diversity Policy
- Health and Safety Policy
- Bullying and Harassment Policy
- Performance Development and Appraisal Policy