Invacare UK Policy 2019 Anti-slavery

Aims of this policy
 
This policy supports our commitment to limiting the risk of modern slavery occurring within our own business or infiltrating our supply chains or any other business relationship.
 
The policy applies to all persons working for or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, volunteers/interns and any other third-party representative.   
 
We expect all who have or seek to have a business relationship with the company to familiarise themselves with this policy and to act at all times in a way that is consistent with its values.
 
We will only do business with organisations who fully comply with this policy (or those who are taking verifiable steps towards compliance).
 
This policy will be used to underpin and inform any statement on slavery and human trafficking that we are required to produce further to the transparency in supply chain requirements of Section 54 of the Modern Slavery Act 2015 (MSA).   
 
Company Description
 
Invacare UK Ltd is a leading disability manufacturer who has helped people with reduced function, mobility and disability live as full a life as possible since 1885. Today, Invacare UK Ltd has a comprehensive product range of mobility, home-care, long-term care and acute equipment.
 
Invacare's UK operations were founded in 1885 and the company now employs 350 people. Based in South Wales, the company is ideally placed to provide the UK healthcare market with a range of products and services that meet the demands of both the public and private sectors
 
What do we mean by modern slavery?
 
Modern slavery can take many forms. It is a complex and multi-faceted problem. The MSA covers four key criminal activities:
 
  • Slavery: where ownership is exercised over an individual
  • Servitude: involves the obligation to provide service imposed by coercion
  • Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty.
  • Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them 
 
Other forms of modern slavery, which we will not tolerate, but are not specifically referenced in the MSA include, but are not limited to:
 
  • Child labour:  whilst not always illegal in the jurisdiction in which it takes place, child labour involves the employment of children that is exploitative, or is likely to be hazardous to, or interfere with, a child’s education, health (including mental health), physical wellbeing or social development.
 
All forms of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.
 
Tackling modern slavery requires us all to play a part and remain vigilant to the risk in all aspects of our business and business relationships.  
 
How we seek to embed our anti-slavery policy in practice 
 
To underpin our policy commitments, we aim to implement the following measures over the course of the financial year 2019 to 2020:
 
Invacare UK Ltd expects that its suppliers will conduct their business in a lawful manner and in compliance with high standards of integrity and ethics. In order to establish guidelines for such standards, Invacare UK Ltd has established a supplier code of conduct. The supplier code of conduct requires supplier compliance with important legal; ethical, behavioural and other requirements specifically, the Supplier Code of Conduct states that suppliers must not support, promote or engage in the practice of slavery or human trafficking, and it requires suppliers to comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
 
If Suppliers or Sub Contractors are found to be in violation of the Supplier Code of Conduct then Invacare UK Ltd will take corrective action to address any deficiencies/ violations identified, Invacare UK Ltd reserve the right to terminate its relationship with any supplier for failure to comply with the Supplier Code of Conduct 
 
While as a company we do not perform routine audits of our suppliers if notice that a supplier is involved in these activities we will conduct an inquiry, or third-party audit if warranted and take appropriate action as required in law.
 
Invacare UK Ltd has established a Code of Business Conduct and Ethics, which applies to all Invacare UK Ltd personnel, including, directors and employees regardless of their employment status. These general principles require all Invacare UK Ltd employees to comply with all applicable laws and regulations, including but not limited to those related to human trafficking and slavery.  The code of Business Conduct and Ethics explains that if an employee needs guidance on a legal or ethical question or has witnessed or has knowledge of illegal or unethical activity, they should consult with or report the matter to their manager, supervisor or via the Company’s Ethics Point Website.
 
All reports for alleged violations will be investigated by Invacare UK Ltd. Disregard or deliberate ignorance of the law, failure to report known potential violations and or failure to cooperate in an investigation will not be tolerated and may lead to disciplinary action, including termination of employment.  
 
Responsibility for this policy
 
The Management team has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.
 
The compliance officer, for Invacare UK Ltd this is our Lead Buyer – Category Sourcing, who will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.
 
All Line Managers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day to day performance of their roles.   
 
Communication and employee awareness training
 
The compliance officer and the HR department will ensure that all relevant employees receive adequate training on this policy and any supporting processes applicable to their role. Such training will form an integral part of the Company’s induction processes.
 
In addition, relevant employees will receive training on the broader issues of modern slavery to assist them in appreciating the extent of the problem of modern slavery and then identify individuals/areas of the business that may be at risk from practices of modern slavery.  
 
Status of this policy
 
This anti-slavery policy will be reviewed by the Company’s Management team on a regular (annual) basis.
 
This policy does not give contractual rights to company employees and we reserve the right to alter any of its terms at any time. We will notify applicable parties in writing of any changes which may affect them.