Modern Slavery Statement

Modern Slavery Statement for Financial Year ending 2023

We remain committed to identifying and preventing modern slavery and human trafficking, not only in our own business but also within our supply chain.  It is an issue which is (and will remain) a priority for us and we expect all of our employees, representatives, distributors and suppliers to share this commitment.

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 2023.

OUR BUSINESS AND ITS STRUCTURE

Following our acquisition by Thermo Fisher Scientific Inc in January 2023, work has been undertaken (and continues to be undertaken) to integrate the practices of The Binding Site with those of the wider 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.

Measures implemented to date include bringing in the robust ethical practices and policies of Thermo Fisher, trained to our staff globally via annual online ethics training.  We have also implemented third party screening platforms for both suppliers and distributors.  Further measures will be implemented over 2024 and details will be available in the next statement.

As a business 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.

We operate internationally through our own subsidiaries and also via a network of distributors.  We operate a zero tolerance approach to modern slavery and human trafficking and this is made known to our network through our due diligence, contractual terms and training.

OUR SUPPLY CHAIN

We continue to source the majority of the goods and services required for the group (including raw materials and components) through a centralised UK purchasing team.  The majority of our suppliers are based in Europe and the United States – both areas with a low prevalence of modern slavery and human trafficking.  As we integrate further into Thermo Fisher Scientific, we will explore opportunities to leverage the supply relationships implemented by the global purchasing team.

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. 

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), 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.  All staff are also required to undertake annual ethics training.

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 modern slavery and human trafficking.  We have recently 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 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 Inc. Supplier Code of Conduct July 2023) which helps us to manage our supplier relationships and ensure that they maintain standards similar to our own.  This 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.  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.  We will be exploring the possibility of providing training to key suppliers in the forthcoming year, as well as new screening platforms to produce compliance scoring reports and develop improvement plans.

Our Staff:

We verify the right to work of each employee by inspecting original passports and visas to ensure that there are no potentially vulnerable employees.  We will only use recruitment agencies and businesses for the supply of staff if they have first passed our due diligence procedures.

Reporting:

As part of Thermo Fisher Scientific, our stakeholders all have access to our anonymous whistleblowing platform and ethics hotline. Any reports are taken very seriously, with investigations and action being undertaken by senior members of our business.

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. 

THE DUE DILIGENCE PROCESS AND RISK ASSESSMENT

Together with the leadership team, the CFO and the Legal team reviews the modern slavery and human trafficking prevention measures on an ongoing basis to ensure continual improvement. 

TRAINING

We continue to train our staff through our Corporate Compliance programme, which includes modern slavery and human trafficking training and how to report it.  

LOOKING AHEAD

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

• providing more in depth training to key staff on modern slavery and human trafficking, including the signs to look for, as well as whistleblowing; and
• implementing the enhanced screening and due diligences procedures offered by our new parent company, Thermo Fisher Scientific Inc

APPROVAL

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