Modern Slavery and Human Trafficking Statement

Introduction

This statement sets out the actions that V-M Orthotics Ltd undertakes to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st January to 31st December 2022.

The following is the process by which V-M Orthotics Ltd assesses  whether particular activities or countries are high risk in relation to slavery or human trafficking. As part of the wholesale industry, and responsible for manufacturing in a number of countries, V-M Orthotics Ltd recognises that it has a responsibility to take a robust approach to slavery  and human trafficking. The company has a zero-tolerance approach to slavery,  trafficking or forced labour in any part of its business and ensures that its supply chains are free from slavery and human trafficking.

The organisation

V-M Orthotics Ltd is a wholesaler of orthopaedic devices and medical footwear. The company is part of the hg DARCO Group, which is made up of the following companies and is controlled by the Board of Directors:

  • DARCO International, Inc
  • DARCO Europe GmbH
  • V-M Orthotics Ltd
  • DARCO Medical India Pvt. Ltd
  • DARCO International Trading Shanghai Co. Ltd

Definitions

V-M Orthotics Ltd considers that modern slavery encompasses:

  • human
  • forced work, through mental or physical
  • being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
  • being dehumanised, treated as a commodity, or bought or sold as
  • being physically constrained or having restrictions placed on freedom of movement.

Commitment

V-M Orthotics Ltd acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The company understands that this requires an ongoing review of  its internal practices in relation to both its direct employees and its supply chains.

V-M Orthotics Ltd does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to V-M Orthotics Ltd in the pursuance of its own activities is obtained by means of slavery or human trafficking. V-M Orthotics Ltd strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom, and in many areas exceeds those standards in relation to its employees.

Supply chains

V-M Orthotics Ltd operates only in the United Kingdom. Employees fall into one of two main categories of employees: warehouse staff and office staff.  The company also uses temporary staff  as the need arises. As the company operates solely in the UK and only employs staff direct, there is little to no scope for any of V-M Orthotics Ltd’s activities to be exposed to slavery or human trafficking.

Our supply chain includes organisations within the manufacturing, shipping and road haulage sectors.  This includes manufacturing of products in other countries, shipping goods from those countries and on rare occasions exporting to customers in Europe, and carriage of goods to customers within the UK.  We also utilise some software products from within Europe.

Potential exposure

V-M Orthotics Ltd considers its main exposure to the risk of slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business, nor in the business of any organisation that supplies goods and/or services to it.

V-M Orthotics Ltd uses temporary staff  as the need arises. As we operate in the UK and only with temporary staff who are known to us, there is little to no scope for any of V-M Orthotics Ltd’s direct activities to be exposed to slavery or human trafficking.

Steps

  • V-M Orthotics Ltd carries out due diligence processes in relation to ensuring slavery and human trafficking does not take place in any of its activities, including conducting a review of the controls of its suppliers.
  • V-M Orthotics Ltd has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
  • In accordance with section 54(4) of the Modern Slavery Act 2015, the company has taken the following steps to ensure that modern slavery is not taking place:

Responsibility

  • hg DARCO Group, and V-M Orthotics Ltd as one of  its associated companies, are 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 company works with suppliers to ensure that they meet the standards of the code and improve their employees’ working conditions.  Serious violations of the company’s supplier code of conduct will lead to the termination of the business relationship.
  • V-M Orthotics Ltd ensures that all overseas  suppliers  who operate on behalf of V-M Orthotics Ltd abide by all laws and relevant legislation. V-M Orthotics Ltd regularly reviews supply chain agreements to ensure that such businesses remain compliant.
  • V-M Orthotics Ltd undertakes due diligence when considering taking on new contracts and reviews its existing contracts annually. V-M Orthotics Ltd has arrangements with third party suppliers, who provide goods and services  including manufactured goods, software, and road haulage/shipping services.
  • V-M Orthotics Ltd has a preferred supplier list for temporary employees and employs those members of staff direct on an ad hoc basis.
  • Responsibility for the company’s anti-slavery  initiatives is as follows:

Policies – the management team is responsible for putting in place and reviewing policies and for the process by which they were developed.

Risk assessments – the management team is responsible for human rights and modern slavery risk analysis.

Investigations/due diligence – the management team is responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking. They will also report any instances that are found to senior management at DARCO International.

Training and awareness

V-M Orthotics Ltd recognises that knowledge is key, and the management team is required to  complete mandatory Modern Slavery training on an annual basis.  The training includes the following aspects:

  • 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 people within the organisation
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies

V-M Orthotics Ltd publishes all policies and procedures internally to ensure employees are aware of not just the company’s responsibility, but their own responsibility to raise any suspicions or evidence of potential slavery or human trafficking issues to the relevant parties within the organisation.  Modern slavery and human trafficking is also raised as an agenda item for discussion at least annually during staff meetings.

V-M Orthotics Ltd will continue to ensure that it and its third-party suppliers are compliant, and that no modern slavery or human trafficking is taking place within its supply chain (both up- and down-stream). V-M Orthotics Ltd will raise awareness of modern slavery more widely, through regular reminders to suppliers and customers and by adding this statement to the company’s internet site.

Policies

Anti-slavery and Human Trafficking Policy  V-M Orthotics Ltd Anti-slavery and Human Trafficking Policy sets out how V-M Orthotics Ltd is committed to ensuring there is transparency in our organisation and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.  We therefore have a specific policy in this regard, which is also linked to our Ethical Employment Standards Policy.

The overarching Ethical Employment Standards Policy  V-M Orthotics Ltd Ethical Employment Standards Policy describes our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking  in its operations,  all of which are accessible to all staff.  This policy incorporates the following aspects which relate to modern slavery and human trafficking:

  • Whistleblowing – V-M Orthotics Ltd operates a code of ethics to which all its workers, customers and other business partners are expected to subscribe. This includes the expectation that all stakeholders will 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 The organisation’s code of ethics is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Child labour – V-M Orthotics Ltd is committed to the principles of protecting children from child labour V-M Orthotics Ltd believes that their future development and that of the communities and countries in which they live is best served through education, not child labour.
  • Dignity at Work – V-M Orthotics Ltd 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

Slavery compliance officer

V-M Orthotics Ltd has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action regarding the company’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed each financial year.

Director approval

This statement has been formally approved and signed by the Director of V-M Orthotics Ltd.

Dated: September 5th 2023

 

Brent Fulks

Director, V-M Orthotics Ltd