Modern Slavery Statement

Modern slavery statement

Organisation

This statement applies to PDI Ltd (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2020/2021.

Definitions

The Organisation considers that modern slavery encompasses:

  • human trafficking
  • forced work, through mental or physical threat
  • being owned or controlled by an employer through mental or physical abuse of the threat of abuse
  • being dehumanised, treated as a commodity or being bought or sold as property
  • being physically constrained or to have restriction placed on freedom of movement.

Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.  No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in [insert countries where your employees are situated.

Supply chains

In order to fulfil its activities, the main supply chains of the Organisation include those related to the supply of medical devices from various suppliers in both the United Kingdom and Italy. We understand that the Organisation’s first-tier suppliers are intermediary traders and therefore, have further contractual relationships with lower-tier suppliers.

Potential exposure

The Organisation considers its main exposure to the risk of slavery and human trafficking to in its medical devices supply chains because they involve the provision of labour in a country where protection against breaches of human rights may be limited.  In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Impact of COVID-19

During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for the Organisation, as it did for others across the nation.  The Organisation welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.

Unfortunately, the Organisation assessed that it would need to delay the publication of this statement for the 2019/2020 financial year due to the impact of COVID-19. It has therefore been delayed for further 6 months. The reason for the delay was due to recent acquisition and integration of companies by PDI International.

The Organisation concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘POTENTIAL EXPOSURE’ above.

The risk of modern slavery increased or did not increase even though its use of suppliers increased due to the fact that demand for our services was significantly higher than normal. Accordingly, the Organisation engaged additional temporary labour from employment agencies in order to meet the need of its customers or its use of suppliers dropped significantly due to the fact that homeworking was swiftly implemented in March 2020 which meant that its premises, from which it usually conducts day to day business, were partially used.

During the pandemic, the Organisation’s employees still had access to the grievance procedure to raise any concerns that they may have had.

In line with emergency legislation passed by the Government, employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking. The Organisation took the decision from the outset of the pandemic to ensure that all of the workforce who were required to self-isolate in accordance with public health guidelines continued to receive pay (according to the government guidelines) during their absence.

The Organisation’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times. 

Steps

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.  The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

    • Adhere to relevant legislation surrounding forced and bonded labour and may choose to sign up to and/or adhere to best practice industry initiatives and codes.
    • Ensure that business partners are aware that they should not use forced or bonded labour.
    • Not use materials or services produced through forced labour.
    • Ensure that employees work voluntarily and not because they have been threatened or intimidated in any way.
    • Reviewing your supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery.
      • Measures in place to identify and assess the potential risks in its supply chains.
      • Undertaking impact assessments of its services upon potential instances of slavery.
      • Creating action plans to address risk to modern slavery.
      • Any actions taken to embed a zero-tolerance policy towards modern slavery.
      • Any training provided to staff on modern slavery.

Policies

The Organisation has the following policies which further define its stance on modern slavery modern slavery policy, a corporate social responsibility policy and recruitment policy.

Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer (HR Manager), to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.