Modern Slavery Statement for Financial Year ending 2024

As part of Thermo Fisher Scientific, our 4i values of Integrity, Intensity, Innovation and Involvement are the foundation of our culture, guiding all our interactions with customers, suppliers, communities and each other. The first of these values, Integrity, reminds our colleagues to honour commitments, communicate openly and demonstrate the highest ethical standards. As such, we remain committed to identifying and preventing human rights abuses, modern slavery and human trafficking, not only in our own business but also within our supply chain.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and provides an update on the actions we have taken (and are continuing to take) to guard against modern slavery and human trafficking in our business and its supply chain, for the financial year ending 31 December 2024.

OUR BUSINESS AND ITS STRUCTURE

As in previous years, we continue to grow at a rapid pace, with more than 90% of our products being sold in countries outside the UK. We are a supplier of specialist, regulated medical diagnostic products which improve the diagnosis and management of blood cancers and immune system disorders. We continue to build on our strong scientific foundations, supporting research and development within our field and responding to the changing needs of patients, researchers and clinicians.

Our production activities are within the UK, and we distribute products and provide our services via our own subsidiaries and an international network of distributors.

There has been a great deal of work undertaken in the last year to integrate the practices of The Binding Site with those of the wider Thermo Fisher Scientific group. We are now able to leverage the strength in depth of the specialist personnel and systems of this larger organisation to continuously improve our own practices.

We continue to implement and roll out the robust ethical practices and policies of Thermo Fisher Scientific, including an overarching Human Rights and Equal Opportunity Policy (the “Human Rights Policy”) which outlines principles and commitments for our operations, including the prohibition of forced labour, prison labour and trafficking of persons; prohibition of child labour; non-discrimination and equal opportunity; fair treatment; adequate wages; benefits and working hours; freedom of association, as well as healthy and safe work standards. This policy applies to all employees, contractors, agents and persons through whom we conduct business.

We use third party screening platforms for third parties with whom we interact as a business to assess “red flags” for those suppliers which provide an indication as to their conduct e.g. adverse news articles/sanctions.

We operate a zero-tolerance approach to forced labour, and this is made known to our suppliers through our onboarding (and then repeated) due diligence, contractual terms and training.

OUR SUPPLY CHAIN

We continue to source goods and services required for the group (including raw materials and components) through a centralised UK purchasing team, but this is now supplemented by access to, and use of, wider Thermo Fisher Scientific supplier relationships which are managed and monitored centrally.

The majority of our suppliers are based in Europe and the United States – both areas with a low prevalence of human rights abuses, modern slavery and human trafficking. We will continue to enhance our supply chain mapping and proactively address any areas of risk we identify. 

OUR POLICIES AND PROCEDURES

Our Staff: All of our staff are required to comply with our Code of Business Conduct and Ethics (Code of Business Conduct and Ethics) (the “Code of Conduct”), which sets out the basis on which we operate as a group of companies. This document is published both internally and externally. Our overarching objective is to act with integrity and in an ethical manner in all of our business relationships. Violations of the Code of Conduct are not tolerated and may lead to disciplinary action. We verify the right to work of each employee by inspecting original passports and vias to ensure that there are no potentially vulnerable employees. We only use recruitment agencies and businesses for the supply of staff if they have first passed our due diligence process.

Our Distributors: Our distributors are carefully chosen for their specialist skills and experience in their territory, and they are vetted before their appointment to assess their working practices, including compliance with legislation on modern slavery and human trafficking. Our distribution contracts require our distributors to comply with legislation, with a right for us to audit performance of their commitments as required. We also require distributors to provide us (on a cyclical basis) with compliance statements, ensuring continued focus on issues such as human rights abuses, modern slavery and human trafficking. We have implemented a third-party platform to manage and screen our distributors which includes completion of regular due diligence questionnaires and receipt of “red flag” alerts if there are any adverse measures recorded against distributors in the media/through sanctions etc.

Our Suppliers: Our suppliers are asked to confirm what steps they are taking to prevent and address the risks of forced labour, child labour, modern slavery and human trafficking in their business prior to their being onboarded as a supplier to our business. This forms part of our supplier due diligence questionnaire which has to be completed for each supplier before they can be used. We have a Supplier Code of Conduct (Thermo Fisher Scientific Supplier Code of Conduct) (the “Supplier Code”) which helps us to manage our supplier relationships and ensure that they maintain standards similar to our own. The Supplier Code includes a requirement to comply with all modern slavery and human trafficking requirements and to comply with the standards set by the International Labour Organisation. The Supplier Code is reviewed and updated on a regular basis, including in 2024.

Our contracts require suppliers to comply with our policies and not to use exploited labour in their organisations and to pass that commitment down to their own suppliers; to comply with all applicable laws, including protective employment and labour laws; to comply with our (and all legal) health and safety requirements and we include within our contracts a right to be able to audit performance and compliance. 

Reporting: We encourage and offer a number of resources for the reporting of illegal or unethical behaviour in our operations or in our supply chain, such as our Global Ethics Hotline (“Global Ethics Hotline”). The Global Ethics Hotline is our telephone and web-based hotline maintained by a third party for the purposes of gathering information regarding compliance and ethics concerns. It is available to colleagues, customers and other external stakeholders such as suppliers and workers in the supply chain, to raise concerns, anonymously if requested, related to any issue, observed or suspected, including human rights issues, violations of law or corporate policies. In addition, and in line with our corporate value of Integrity, anyone can report human rights, ethics and compliance related concerns directly to any level of internal leadership, our legal or human resources teams. Reports of violations are rigorously investigated and documented. Our non-retaliation policy ensures that retaliation against any person who lawfully and in good faith seeks advice, raises a concern, reports misconduct or provides information in an investigation is strictly prohibited and will not be tolerated. The Supplier Code also prohibits supplier unlawful retaliation against its employees for reporting violations or co-operating in any investigation.

GLOBAL SLAVERY INDEX

We undertake specific checks to identify any distributors and suppliers based in countries considered to be high risk on the Global Slavery Index. The onboarding and use of any supplier and/or distributor in a high-risk country must be approved at Board level before their appointment and before orders are placed. 

MONITORING OUR EFFECTIVENESS

We continually review and improve our practices to identify and eliminate forced labour, child labour and modern slavery, as well as human rights abuses as far as possible. To do this, we are:

• improving our risk assessment tools for suppliers;
• monitoring and improving supplier diligence response rates;
• monitoring the effectiveness of mandatory ethics training, including looking at response rates; question and answer sections; and employee attestation of completion; and
• monitoring the efficient resolution and remediation of any complaints received in relation to human rights in our operations.

LOOKING AHEAD

We are continuing to reinforce our commitment to proactively identifying and preventing modern slavery and human trafficking by:

• implementing the enhanced screening and due diligences procedures offered by Thermo Fisher Scientific, including more detailed supply chain reviews; supplier assessments and access to supplier and staff training;
• reviewing and implementing revised government advice respecting legislation relating to human rights abuses, forced labour, child labour and modern slavery; and
• becoming part of the Thermo Fisher Scientific reporting and monitoring systems for the purposes of forced labour, modern slavery, child labour and human rights abuses.

APPROVAL

This statement has been approved by the leadership team of The Binding Site Group Limited