Modern Slavery and Human Trafficking Statement
MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
Introduction
This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 30 April 2023.
Super B Plus Group Ltd ('the Company', 'we', 'us' or 'our') is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.
Organisational Structure
Super B Plus Group Ltd and has business operations in the United Kingdom, as well as:
- globally
We operate in the life sciences sector. The nature of our supply chains is as follows:
- We work with a number of suppliers, customers, contract manufacturers, distributors, and logistics partners.
For more information about the Company, please visit our website: https://www.superbplusgroup.com
Policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.
These include the following:
- Whistleblowing policy -
Under certain circumstances, employees are protected from suffering any detriment or termination of employment if they make disclosures about organisations for whom they work.
- Anti-bribery Policy -
It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
- Equality, Inclusion and Diversity Policy -
The aim of the policy is to ensure no job applicant, employee or worker is discriminated against either directly or indirectly on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex, or sexual orientation.
- Disciplinary Policy -
The aim of our disciplinary rules and procedures is to establish and maintain appropriate standards of conduct at work.
- Grievance Procedure -
The grievance procedure is designed to ensure that concerns and problems arising during the course of employment can be aired and, where possible, resolved.
- Harassment Policy & Procedure -
This policy states that harassment or victimisation on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation is unacceptable.
We make sure our suppliers are aware of our policies and adhere to the same standards.
Due Diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:
- Internal supplier audits.
- Standard Operating Procedures for Quality Risk Management - Risk Assessments.
- Staff Trainings and Standard Operating Procedures for training process.
- Standard Operating Procedures for Falsified Medicines Directive operations and for Prevention of Counterfeit Medicines Procedures.
- Standard Operating Procedures for New Account Opening procedures for customers & suppliers.
- Standard Operating Procedures for importing and exporting medicines from the EEA Market & other countries.
- Standard Operating Procedures for Ordering & Selling Goods and Services to customers & suppliers.
Our due diligence procedures aim to:
- Identify and action potential risks in our business and supply chains.
- Monitor potential risks in our business and supply chains.
- Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
- Provide protection for whistleblowers.
Risk and Compliance
The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:
- Evaluating the slavery and human trafficking risks of each new supplier.
- Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping. We will contact suppliers to enquire about their modern slavery practices every 12 months.
- We will train our staff about modern slavery issues and increase awareness within the Company.
- We will carry out a regular audit of suppliers.
We do not consider that we operate in a high-risk environment because
The business operates in this risk level environment because the majority of our supply chain is based in the UK and in low-risk industries, such as life sciences. If the supply chain is located outside UK we have many existing long-term business partnerships, which involve less risk. We also supply low risk products such as pharmaceutical products, food supplements, nutraceuticals, cosmeceuticals, equipment and medical devices, and other products to improve the lives of organisms, which require highly qualified skilled workers.
We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.
Effectiveness
The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:
- We will contact suppliers to enquire about their modern slavery practices every12 months.
- We will train our staff about modern slavery issues and increase awareness withinthe Company.
- We will carry out a regular audit of suppliers
Training Staff
The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company’s training covers:
- 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 parties within the Company.
- What external help is available.
- What steps the Company should take if suppliers in its supply chain do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chain.
The statement was approved by the board of directors and signed by Quality Manager.
Dorota Zareba (Feb 2, 2024 23:19 GMT)
Dorota Zareba, Quality Manager / Project Manager
Super B Plus Group Ltd
Date: 02/02/2024