1. Introduction
1.1 IVAN SPINAL SURGERY LTD (the “Company”) is committed to preventing slavery and human trafficking in its business activities and supply chains. The Company acknowledges its responsibility under the UK Modern Slavery Act 2015 to ensure that slavery and human trafficking do not take place in any part of its business or supply chains.
1.2 This Anti-Slavery Policy sets out the Company’s approach to ensuring that slavery and human trafficking are not present in its business activities or supply chains.
2. Definitions
2.1 For the purposes of this policy, the following definitions apply:
- “Modern Slavery” means any conduct or activity which constitutes an offence under the UK Modern Slavery Act 2015, including slavery, servitude, forced or compulsory labour, and human trafficking.
- “Supply Chains” means all stages of the production and distribution of goods and services, from the acquisition of raw materials to the delivery of finished products or services to end customers.
- “Third Parties” means any person or entity that is not an employee or officer of the Company, including but not limited to suppliers, contractors, agents, distributors, and joint venture partners.
3. Policy Statements
3.1 Compliance with the Modern Slavery Act 2015
The Company is committed to complying with the UK Modern Slavery Act 2015 and will take all necessary steps to ensure that slavery and human trafficking are not taking place in any part of its business activities or supply chains.
3.2 Due Diligence
The Company will conduct due diligence on its supply chains to assess the risk of modern slavery and human trafficking. This may include reviewing supplier contracts, auditing suppliers, and conducting risk assessments. The Company will take appropriate action to address any identified risks.
3.3 Supplier Code of Conduct
The Company expects its suppliers to comply with the UK Modern Slavery Act 2015 and to implement policies and procedures to prevent modern slavery and human trafficking in their own supply chains. The Company will include a requirement for compliance with this policy in all supplier contracts.
3.4 Training
The Company will provide training on this policy and the risks of modern slavery and human trafficking to all employees who are involved in procurement or supply chain management. The Company will also provide training to its suppliers where appropriate.
3.5 Reporting
The Company encourages employees, suppliers, and other stakeholders to report any concerns or suspicions about modern slavery and human trafficking in the Company’s business activities or supply chains. The Company will investigate all reports and take appropriate action where necessary.
4. Responsibilities
4.1 The Board of Directors is responsible for ensuring that the Company complies with the UK Modern Slavery Act 2015 and that this policy is implemented effectively.
4.2 The Chief Executive Officer is responsible for ensuring that all employees are aware of this policy and that appropriate training is provided.
4.3 All employees and officers of the Company are responsible for ensuring that they comply with this policy and report any concerns or suspicions about modern slavery and human trafficking.
5. Review
5.1 This policy will be reviewed annually to ensure that it remains effective and up-to-date. Any necessary updates or amendments will be made and communicated to employees and suppliers.
Last update: 15.3.2023.
