JRI Orthopaedics Ltd modern slavery

Policy statement

1.2 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and aim at all times to act ethically and with integrity in all our business dealings and relationships.

1.3 We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in our supply chain. We will provide transparency in own business dealings, consistent with the disclosure obligations under the Modern Slavery Act 2015.

1.4 We expect all our contractors, suppliers, potential suppliers, and partners to maintain high ethical standards and to operate in an ethical, legally compliant, and professional manner. We also expect our suppliers to promote compliance with this policy and the Modern Slavery Act 2015 within their own supply chains.

1.5 This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

2 Who is covered by the policy?

2.1 This policy applies to all persons working for us or on our behalf in any capacity, including (but not limited to): Board members, directors, all employees at all levels (whether permanent, fixed term or temporary, agency workers and interns, contractors, external consultants, third-party representatives, suppliers, and business partners).
2.2 The Management Board has overall responsibility for ensuring that this policy complies with our legal and ethical obligations, and that all those covered under this policy comply with it.
2.3 The HR Manager has primary and day to-day responsibility for monitoring this policy’s use, effectiveness, and currency, and for dealing with any queries about its application and meaning.
2.4 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are provided with adequate and regular communications on it and the issue of modern slavery in supply chains.
2.5 This policy will be subject to annual reviews overseen by the Management Board.

3 Organisation and responsibilities –
The Company will ensure that:
3.1 Employees shall be free to choose to work for and to leave the company upon reasonable notice.
3.2 All employees will be provided with a clear contract of employment, which complies with current legislation.
3.3 All employees will be treated in a fair and equal manner and with dignity and respect.
3.4 Any form of discrimination, victimization, or harassment on any grounds including, but not limited to, marital or civil partnership status, sex (including gender reassignment), race (including colour, ethnic and national origin, nationality), disability, sexual orientation, having or not having dependents, religious belief or political opinion, age, trade union activity and offending background will be prohibited.
3.5 All applicable laws and industry standards on employee wages, benefits, working hours and minimum age should be adhered to in all countries of operation, without any unauthorised deductions. Suppliers should observe the provisions of the International Labour Organization such that any young persons under the age of 18 should not be employed to work at night or for any hazardous work and their employment should not harm the young person’s education, health or physical, mental, moral, or social development. No young persons may be employed below the age of 16.
3.6 Strict compliance checks are carried out for all candidates. We will verify the identity of each
worker and their right to work before supply commences.
3.7 As part of our commitment to identify and eradicate slavery, human trafficking, and child labour, we have in place a process to undertake due diligence on our supply chain network to ensure compliance with legislative obligations: such compliance forming part of our contractual relationship with suppliers.
3.8 We require all our suppliers to adhere to the standards set out by the International Labour
Organisation as regards the employment of children and young people. In particular: (a) children must not be recruited before they have reached the age of completion of compulsory schooling, and in any case not before the age of 16; and (b) those under 18 must not be required to perform hazardous duties.

4. Compliance
4.1 The arrangements made to implement this policy are defined and documented in the Company Integrated Management System and in Departmental Work Instructions.
4.2 All employees, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partner must therefore ensure that they have read, understood, and comply with this policy.
4.3 The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to a breach of this policy and are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
4.4 You must notify the Management Board, Managing Director or HR Manager, in accordance with our Whistleblowing Policy (S.27 Employee Handbook), as soon as possible if you believe or suspect a breach of this policy or a conflict with this policy is occurring, has occurred, or may occur in the future.
4.5 JRI is committed to protecting employees when disclosing malpractice and will ensure that all disclosures made in good faith will be treated confidentially and without fear of retaliation.
4.6 As a priority, we will give support and guidance to our suppliers to help them address coercive, abusive, and exploitative work practices in their own business and supply chains.
4.7 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager, or, if it is not appropriate to do so, with the HR Manager or Management Board.
4.8 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains or partner organisations. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the HR Manager or Management Board immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

5 Organisational Learning Culture
5.1 The Company and its employees have a responsibility to help build the Company’s capability by developing skills, knowledge, and experience. The success of the Company depends to a large extent upon our ability to continually develop new and relevant skills, share our knowledge effectively, learn from our collective experience and so enhance our competitiveness.
5.2 All workers are expected to take part in relevant learning and development activities prescribed by the Company.
5.3 All workers are expected to comply with the law and act in accordance with local guidelines and regulations and to act, at all times with integrity and honesty.