Modern Slavery Policy

Introduction

This Modern Slavery Policy and Statement sets out Pasante Healthcare Ltd’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

The organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its activities, and to ensuring that its supply chains are free from slavery and human trafficking.

This Policy and Statement covers the activities of Pasante Healthcare Ltd:

  • Pasante Healthcare Ltd is part of the Karex Berhad Group of companies and distributes healthcare products (including, but not limited to condoms, lubricants, pregnancy & INSTI HIV test kits and 3rd party distributor products) to the NHS and Retail sectors, both domestically and abroad. 
  • Products are purchased from a number of countries (including, but not limited to Malaysia, Thailand, US, Spain, China, Czech Republic.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners.

We do not accept any form of discrimination, harassment or bullying within Pasante or its supply chain. We require all of our managers and leaders to implement processes designed to ensure equality of opportunity and inclusion for all employees as well as for individuals employed in our supply chain. Being aware of the extremely complex nature of modern slavery, we continue to emphasize the importance of collaboration and learning from others, including by engaging with human rights NGOs at Group level.

In regard to forced labour, human trafficking and child labour, in the conduct of its business, Pasante:

  • Will not coerce workers through the use of violence, intimidation, accumulated debt, retention of identity papers or any other means.
  • Will not transport people from one country or region to another for the purposes of forced labour or sexual exploitation.
  • Will comply with all applicable labour laws, including those related to wages, hours worked, overtime and working conditions;
  • Will not employ children that fall into the definition as stipulated by ILO Convention, notwithstanding any national law or local regulation;
  • The company does not provide employment to children before they have reached the legal age to have completed their compulsory education, as defined by the relevant authorities;
  • Expects its business partners and associates to have and uphold similar standards and abide by country-governing laws in countries wherein they operate. Should violation of these Principles become known to Pasante and not be remediated, we will take serious action, including discontinuation of the business relationship;
  • Develop a remediation plan that secures the children’s education and protects their economic well-being, in consultation with Karex and where possible a local NGO, and in consultation with and respecting the views of the child;
  • Seek advice and help from a recognized local non-governmental organization that deals with child labour or the welfare of children.

 

It is the responsibility of the local Senior Management and Human Resource Department to implement and ensure compliance with this policy.

 

The following is the process by which Pasante assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

 

  • Identify and assess potential risk areas when considering taking on new suppliers and regularly review our existing supply chains.
  • Review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.
  • Protect whistle blowers.
  • Work with Suppliers to develop and implement appropriate internal business processes to ensure compliance with Pasante and Group supplier pre-assessment process.
  • If a supplier fails to uphold any aspect of the requirements of the supplier pre-assessment process and guidelines, the supplier is expected to implement corrective actions.

Responsibility

Responsibility for the organisation's anti-slavery initiatives is as follows :

Policies: Appropriate senior Management: Pasante local level, Karex group HR – Human Rights; Modern Slavery; Pasante Purchasing local level, Karex Supply Chain Director – Supplier Code of Conduct.

Risk assessments: Senior Management at local and Group level, as above.

Investigations/due diligence: HR and Supply chain Department (local and Group level).

Training: Through induction, head of department training, recruitment and ongoing training.

 

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations [select the relevant policies from the list below and include links to the full text]:

  • Whistleblowing policy Pasante encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use the Group confidential helpline/complete the local confidential disclosure form.
  • Employee code of conduct The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Supplier code of conduct The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.
  • Recruitment/Agency workers policy Pasante uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due diligence

Pasante undertakes to exercise due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews will include:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits or assessments through [the organisation's own staff/third party auditor], which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • creating an annual risk profile for each supplier;
  • taking steps to improve substandard suppliers' practices, including providing advice to suppliers through [third party auditor] and requiring them to implement action plans;
  • participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
  • using for example Sedex, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

Pasante has reviewed its key performance indicators (KPIs). As a result, the organisation will

  • require all supply chain managers/HR professionals to have completed training on modern slavery by end of 2019.
  • develop a system for supply chain verification expected to be in place by end of 2019 whereby the organisation evaluates potential suppliers before they enter the supply chain; and
  • review its existing supply chains expected to be completed by end of 2019, whereby the organisation evaluates all existing suppliers.

Training

The organisation requires supply chain managers/HR/QA professionals within the organisation to complete training on modern slavery.

The organisation's modern slavery training will cover:

  • our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.

Awareness-raising programme

As well as training staff, the organisation will raise awareness of modern slavery issues by putting up flyers/posters across the organisation's premises/circulating a series of emails to staff.

The flyers/posters/emails will explain to staff:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.

This statement was approved on 31st August 2019 by the organisation's Directors, who will review and update it annually.