Modern Slavery Policy

Modern Slavery / Labour Standards Policy


Level 2 LSAS Certification awarded by International Associates in December 2019



TRB Chemedica (UK) Ltd. Labour Policy is outlined within the Labour Standards Assurance System, initial publication dated 4th September 2019. It clearly applies to both the internal organisation, and its supply chain and is approved by senior management: Mr Alex Flanagan, Managing Director.
It commits to continual improvement and sets out 7 core minimum labour standards.
Adequate resources will be made available to the LSAS, and this manifests in both time and financial backing.
It is appropriate to TRB Chemedica (UK) Ltd., as its scope includes the following: Supply and distribution of medical devices. 
It was communicated to all employees and evidence retained. The key suppliers were also sent a copy of the policy, with a requirement that they pass on through the supply chain.  
It is publicly available and to validate this, it will be posted on the company's website.
This Ethical Labour Standards Policy will be reviewed annually, and evidence of that review will be contained in the minutes of the Management Review Meeting.
TRB Chemedica (UK) Ltd. also requires its suppliers to comply with their national laws along with the principles held within the LSAS Specification and the base code of the Ethical Trading Initiative. 

Minimum Labour Standards

The Company has identified the following compelling reasons to establish a comprehensive system of Minimum Labour Standards to guide it in its business operations.

1. ETHICAL RESPONSIBILITIES - the Company acknowledges its obligations towards its customers, employees and the communities in which it works arising from its business operations and wishes to work and trade in an ethical fashion.

2. THREAT TO SECURITY OF SUPPLY – the Company has identified that labour standards abuse in supply chains can pose a risk to the security of supply. Any supply chain partners perpetrating abuses face legal enforcement action which may damage business and interfere with their ability to continue to supply.

3. ADVERSE PUBLICITY AND DAMAGE TO THE COMPANY’S REPUTATION – adverse publicity from the discovery of labour standards abuses in the Company’s supply chain presents reputational and structural risks as follows – (a) income – customers may choose to purchase supplies and services from other providers (b) staff recruitment and retention –staff may choose not to work for a Company associated with any labour standards abuses and this may lead to poor morale in the work place and difficulty in recruitment (c) loss of trust – both with customers and suppliers and also within the wider community.

4. REDUCED QUALITY OF GOODS AND SERVICES – the Company recognises that there is commonly a link between poor labour standards and poor quality of goods and services. To this end, it is in the interest of the Company to ensure its suppliers reach minimum labour standards targets at all times.

These minimum labour standards are: -

1. Child Labour – the Company does not engage in or support the use of child labour. If the company engages any young workers, it will ensure that a suitable risk assessment is carried out and that young persons are not exposed to any hazardous conditions, or in any case work more than 8 hours per day.

2. Forced & Compulsory Labour – the Company shall not engage in or support the use of forced or compulsory labour, or bonded or involuntary prison labour. Employees are free to leave upon reasonable notice.

3. Health & Safety – the Company shall provide a safe and healthy workplace environment and shall take effective steps to prevent potential accidents and injury to employees’ health by minimizing, so far as is reasonably practicable, and in co-operation with its employees, the causes of hazards inherent in the workplace. All employees will receive safety and job specific instructions during the course of their employment with the company. Employees shall have access to clean sanitary facilities and drinking water. Responsibility for implementing the Health & Safety element of this policy is assigned to the Managing Director.

4. Freedom of Association – the freedom of association is respected, and the Company will comply with UK labour relations legislation in this regard.

5. Discrimination – the Company shall not engage in or support any discriminatory practices in hiring, remuneration, access to training, promotion, termination or retirement based on race, national or social origin, caste, religion, gender, sexual orientation, political affiliations, age or other conditions that could give rise to discrimination. The Company has an Equal Opportunities and Diversity Policy which is shown to all new employees at induction.

6. Disciplinary Practices – the Company shall treat all employees with dignity and respect. The Company shall not engage in or tolerate the use of corporal punishment, mental or physical coercion or verbal abuse of personnel. No harsh or inhumane treatment is allowed.

7. Working Hours – the Company shall comply with applicable laws and industry standards on
working hours and holiday entitlements. The Company’s normal working hours do not exceed 48 hours per week, and overtime hours do not exceed 12 hours per week. The Company ensures all employees have the legal right to be employed in the UK.

8. Remuneration - the Company shall comply with national laws and regulations regarding wages and benefits. All work-related activities are carried out on the basis of a recognised employment relationship established according to national law and practice. 

A Flanagan
Managing Director