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TACKLING MODERN SLAVERY

UK MODERN SLAVERY ACT DISCLOSURE STATEMENT 2020

This Disclosure Statement (“Statement”) has been published pursuant to section 54(1) of the UK Modern Slavery Act 2015 (“the Act”) and is made on behalf of Pure Medical Group Limited and all subsidiary companies which are in scope for the purposes of the Act (and together are referred to herein as “Pure Medical”).

The main driving force behind this measure is to prevent modern slavery in organisations and their supply chains. At Pure Medical, we feel one of the best ways to achieve this is to increase transparency by ensuring our community, employees, customers and the public know what steps our organisation is taking to tackle modern slavery. Pure Medical is committed to epically high standards of ethical conduct and compliance with applicable laws and we fully expect all of our suppliers to conduct themselves in exactly the same manner.

At Pure Medical we are committed to ethical conduct and compliance with laws prohibiting human trafficking and slavery. The UK Modern Slavery Act 2015 defines “modern slavery” as including the offences of “slavery, servitude and forced or compulsory labour” as well as “human trafficking”, all of which are directly opposed to the values and ethics of our company (and frankly, all companies we want to be associated with!). We want our company to be a force for good and will always ensure that there is absolutely no human trafficking and forced labour activities anywhere within our organisation or our supply chain.

ABOUT PURE MEDICAL

Pure Medical is a healthcare provider. While the majority of our owned and operated sites are based in the U.K., we currently also have laboratories located in Cyprus and Mainland Europe – it’s like the greatest game of Risk ever! We also work with a growing number of Franchise partners in key markets such as India, Singapore, Finland and others.

OUR PEOPLE

We are a UK Living Wage employer. We occasionally make use of agency workers, and we engage a number of third parties to supply people to work in our organisation. We make it a priority to evaluate and understand the agencies which provide such people and we always ensure that the contracts between us have the necessary controls and procedures in place to address the Modern Slavery Act. We protect all people working within our clinics, depots, offices and laboratories from any form of exploitation. Compliance with all aspects of employment law is an absolute must within our business and is expected from all our suppliers.

OUR BUSINESS AND SUPPLY CHAIN

Pure Medical purchases the highest quality goods and services from suppliers all over the world, while trying to purchase locally as much as we can. Pure Medical will only ever do business with awesome suppliers who believe in things we believe in and as part of us selecting who we work with we always make sure that they are fully compliant with all anti-slavery and human trafficking laws in the countries in which they operate. We fully expect them to have suitable anti-slavery and human trafficking policies and processes in place, all of which forms part of our New Vendor process when we onboard new suppliers. If an organisation doesn’t make the cut, then we won’t work with them. Ever.

We have identified that clothing and merchandise suppliers are potentially high risk (due to the nature of clothing manufacture and the risk of unethical business practices within that industry) and any new merchandise supplier must provide independent evidence of their adherence to the applicable laws and regulations. Although this is only a small part of our revenue stream it’s essential to us that any goods manufactured for us are done so in the right way – exactly as you would expect.

Pure Medical expects its key suppliers to follow the Corporate Code of Ethics published by CIPS (Chartered Institute of Procurement and Supply) www.cips.org/en-GB/who-we-are/governance/cips-code-of-conduct/.

The Code sets out the values, business culture and practices which all organisations can adopt. The Code requires a commitment to the eradication of unethical business practices, including bribery, fraud, corruption and human rights abuses, such as modern slavery and child labour.

Pure Medical POLICIES

Pure Medical actively complies with the employment laws in every country in which we operate. Pure Medical does not and will never use child forced labour, we have a zero-tolerance approach to anyone who does. If Pure Medical uncovers any evidence of forced labour within a supplier or potential supplier, we shall immediately cease conducting business with them. If we find evidence of child forced labour, we will ensure a remediation plan is put in place to ensure the eradication of that child forced labour.

Pure Medical does not allow or condone physical punishment or abuse, again here if we uncover any evidence within a supplier or potential supplier we shall immediately cease conducting business with them.

Pure Medical respects the freedom of individual employees to join, or refrain from joining, legally authorised associations or organisations.

Pure Medical fully complies with all applicable laws prohibiting human trafficking.

TRAINING

Pure Medical has an expansive learning & development programme which outlines our expectations in relation to, among other things, anti-corruption, respect in the workplace, and generally making sure that we are compliant with all necessary global regulations. We strive to ensure that all of our crew hold our values and ethics at their core. Crew Members are encouraged to raise legal or ethical concerns though various reporting channels such as their line managers, another member of management, the People Team, or directly with the Board of Directors, or our confidential helpline, DogWatch.

Pure Medical FRANCHISE

Our global Franchise Agreements have very strict standards and adherence to anti-slavery and human trafficking laws is an integral part of being a Pure Medical Franchise partner. We conduct detailed diligence on all potential Franchisees and only those with the highest standards will make the grade. We audit our partners regularly and we will not tolerate any breaches of the relevant laws and regulations. We regularly provide training to our Franchise partners to instil the highest standards of service, staff treatment, and ethical working in the Franchise ecosystem. If it wouldn’t happen in one of our own sites, then it won’t happen in a Franchise location.

PURE MEDICAL COMMITTMENT

In 2021 Pure Medical will implement the following initiatives in order to evolve our processes, improve our understanding and ensure we minimize any potential for human trafficking and forced labour activities within our supply chain;

  • Build a risk matrix based on goods and services provided to Pure Medical to identify areas of the business where there is the most potential for human trafficking and forced labour activities.
  • Create and roll out an e-learning module for all Pure Medical staff to increase awareness.
  • Every new contract will include a positive disclosure statement from our suppliers, this statement will ensure that our suppliers fully comply with all applicable laws prohibiting human trafficking and forced labour.
  • All new suppliers who work with Pure Medical will sign up to our procurement standards which include a zero-tolerance to any human trafficking and forced labour practices.