Modern Slavery and Human Trafficking Statement 2024
medneo UK Limited (and associated subsidiaries: medneo Diagnostics UK Ltd and medneo Logistics UK Ltd)
medneo UK Limited and its subsidiary companies (“the Company”) is committed to ethical, transparent, and responsible business practices. We take a zero-tolerance approach to modern slavery and human trafficking in all forms. This statement outlines the actions we have taken and continue to take to ensure that modern slavery and human trafficking do not occur within our operations or supply chains. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and relates to the financial year ending 31st December 2024.
Our Business and Organisational Structure
The Company provides advanced diagnostic imaging services to healthcare providers across the UK. As part of our operations, we work with a global network of suppliers and partners. Our organisational structure is designed to mitigate the risk of modern slavery by ensuring that ethical labour practices are embedded in both our supply chain and operational activities.
To address modern slavery risks, our organisational structure includes:
- Confidential whistleblowing channels available for employees and suppliers to report any concerns related to modern slavery or human trafficking.
- Documented escalation pathway to ensure the Company’s staff have a route to report concerns to their manager and the Company’s Board
Our Policies
Our policies underpin our commitment to tackling modern slavery, including:
- Modern Slavery Policy: Reinforcing our stance against modern slavery and human trafficking across all aspects of our business and supply chain.
- Customer onboarding Policy: Providing a mechanism for the manager responsible for onboarding a customer to confirm the necessary checks have been satisfactorily completed.
- Whistleblowing Policy: Providing a safe and confidential mechanism for employees, suppliers, and partners to raise concerns about unethical practices, including modern slavery.
Due Diligence in Procurement
The Company implements rigorous due diligence processes in our procurement activities to minimise the risk of modern slavery in our supply chain. These processes include:
- Conducting risk assessments of suppliers based on factors such as geography, industry, and the nature of the goods or services provided.
- Incorporating anti-slavery clauses in all supplier contracts, requiring full compliance with the Modern Slavery Act 2015 and our Supplier Code of Conduct.
- Performing regular audits on high-risk suppliers to verify their adherence to ethical standards.
- Collaborating with suppliers to address any identified risks or concerns, promoting continuous improvement in their practices.
Performance Indicators
The Company monitor the effectiveness of its modern slavery prevention efforts through several key performance indicators (KPIs), which are reviewed annually. These include:
- Supplier audits: The Company aims to increase the number of audits conducted, focusing on suppliers in high-risk regions and sectors.
- Training completion rates: Tracking the percentage of relevant employees who have completed modern slavery training.
- Incidents reported and resolved: Monitoring the number of modern slavery-related concerns raised and successfully resolved through our whistleblowing and incident reporting channels.
Training and Awareness
Training plays a crucial role in the Company’s strategy to combat modern slavery. The Company provide mandatory modern slavery training for all managers and those employees who are involved with direct communication when contracting suppliers.
The training includes:
- Information on modern slavery and human trafficking, including how to identify potential signs of exploitation.
- Healthcare specific scenarios to ensure the training is appropriate.
- Guidance on raising safeguarding issues (adults and children) where a Company’s employee has concerns about potential slavery.
The Company encourages its suppliers to provide similar training for their employees, further promoting ethical practices throughout the supply chain.
Ongoing Commitment
The Company is committed to continuous improvement in our approach to preventing modern slavery and human trafficking. The Company will regularly review and enhance our policies, procedures, and practices to ensure they remain effective. Its commitment extends to working closely with suppliers, partners, and stakeholders to uphold ethical standards throughout our operations and supply chains.
This statement has been approved by the Board of Directors of the Company and will be reviewed and updated annually to reflect our ongoing progress.
Andrew M. Spellman
CEO