Modern Slavery Policy

Introduction

According to a recent report by the Shiva Foundation, around nearly 12,000 people are involved in modern slavery in the UK, from goods produced by forced labour to staff being forced to work against their will and hotels being used for sexual exploitation. Victims are said to often be unaware that their treatment is illegal.

Purpose

Thermapen is committed to understanding modern slavery risks; and ensuring that there is no modern slavery in our own business and supply chains. We confirm that the organisation complies with all applicable anti-slavery and human trafficking laws, in particular, but not limited to, the Modern Slavery Act 2015. This includes compliance with the principles of the Ethical Trade Initiative as set out in our Ethical Trading Policy. The principles of the Ethical Trading Initiative may be found at – http://www.ethicaltrade.org/eti-base-code

Scope

This policy applies to all permanent and temporary employees of the Company (including any of its intermediaries, subsidiaries or associated companies). It also applies to any individual or corporate entity associated with the Company or who performs functions in relation to, or for and on behalf of, the Company, including, but not limited to, directors, agency workers, casual workers, contractors, consultants, agents and suppliers (“associated persons”). All employees and associated persons are expected to adhere to the principles set out in this policy.

Legal Obligations

The key UK legislation on which this policy is based is the Modern Slavery Act 2015 and applies to the Company’s conduct both in the UK and abroad. Although Thermapen remains under the annual turnover prescribed by the regulations, it recognises the issues associated with the principles of this legislation. All Directors and Managers have been trained in respect of the Modern Slavery Act 2015 and the base-code of the Ethical Trading Initiative, including due diligence required when considering taking on new employees and/or suppliers, and how existing suppliers are reviewed. The company will publish confirmation of compliance on their website, however, at this stage, there will be no confirmation of any reviews undertaken. Details of the Act and the government issued document, ‘Transparency in Supply Chains’, may be found at:

Policy

All persons, as described under Scope, are required to follow the principles and legislative requirements of both the Ethical Trading Initiative and the Modern Slavery Act 2015. Whilst the Company recognises that employment practices may vary from country to country or from culture to culture, Thermapen is pleased to support this initiative and legislation in an attempt to eradicate the heinous crimes associated with slavery and human trafficking. It is the responsibility of everyone to recognise and report any activity or situation that could be construed as contrary to the principles outlined above.

Monitoring

The Managing Director is responsible for ensuring compliance with this policy and will review its contents on a regular basis with the Board who have overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations. If it comes to the notice of the Board of Directors that this policy has been disregarded, or its principles and the law abused by any member of staff, contractor, supplier, or even a customer, the matter shall be discussed by the Directors and a decision made as to the actions of the company. Consequences that may be considered include; formal disciplinary action with employees; sanctions against contractors or suppliers and possible reporting to authorities in any event. Any such actions will be documented.