ADM-PO-07A: Anti-slavery and human trafficking statement
Rev 7 | Date: Jul 2025
1. Policy
The Drive DeVilbiss Healthcare Ltd (the Company) group of companies prohibits slavery, forced labour and human trafficking of any kind in relation to our business operations and our supply chains. The Company has a zero-tolerance approach to any form of modern slavery or human trafficking. The Company supports the promotion of ethical business practices and policies to protect workers from any kind of abuse or exploitation in relation to our group businesses and supply chains.
2. Our Group of businesses
Drive DeVilbiss Healthcare is a leading manufacturer and distributor of durable medical equipment, mobility products, respiratory and sleep aids, pressure care products, and specialist seating and mobility aids. The group includes the following businesses:
- Drive DeVilbiss Healthcare Ltd.
- Drive DeVilbiss Sidhil Ltd.
- Specialised Orthotic Services Ltd.
3. Communication, compliance, and risk assessment
In the last year, the Company has taken the following steps in relation to its policy on anti-slavery and human trafficking:
- ADM-PO-01 SHEQ policy Rev 27
- ADM-PO-06 Ethical policy Rev 10
- ADM-PO-07 Anti-slavery & human trafficking policy Rev 7
- ADM-PO-45 External whistle blowing policy Rev 1
Employees are trained on these policies and complete an E-Learning programme. These policies are issued to existing and new suppliers along with standard purchasing terms and conditions. Adherence to these policies is a condition of trading with the Company and they are re-issued throughout the supply chain as they are updated. Procedures to meet the requirements of the SA8000 Social accountability management standard are integrated within the Company's management systems manual.
The Company has achieved the following LSAS levels:
- August 2017: Assessed by SGS for LSAS against the SA8000 Social Accountability Management Standard and attained LSAS Level 1.
- December 2017: Attained LSAS Level 2.
- August 2020: Attained LSAS Level 3.
- September 2021: Attained LSAS Level 4 in two criteria areas and Level 3 in the remaining thirteen criteria areas.
- August 2023: Maintained LSAS Levels; 2 criteria areas at Level 4, and 13 Categories at Level 3.
4. Supply chain
The Company continually assesses its suppliers in the UK and overseas for risk. Most purchased products are imported into the UK and are machine manufactured goods rather than labour-intensive handmade products. The highest-risk areas are considered to be suppliers outside of the UK and EU, including component suppliers, raw material suppliers, third party manufacturers, service providers, and sub-contractors.
To mitigate risks, suppliers in all countries are required to complete a supplier evaluation form that includes a section on social accountability and labour standards. The Company makes its stance clear to employees, the supply chain, and other affected parties by following the guidance set out within the Ethical Trading Initiative Base Code, included in the Ethical Policy ADM-PO-06.
5. Supply chain Key performance indicators
To assess the effectiveness of measures taken to ensure slavery or human trafficking is not occurring within the business or supply chain, the Company checks that:
- No reports have been received from employees, the public, or law enforcement agencies indicating modern slavery within the business or supply chain.
- No irregularities are identified on audits of suppliers.
- Online searches of key suppliers have not identified any suppliers convicted of offenses relating to modern slavery or human trafficking.
6. Breaches
In the event of any suspected failure by a supplier to comply with our Policies, the circumstances will be investigated. If a breach is identified, appropriate remedial action will be required from the supplier, and the trading relationship may be monitored, suspended, or terminated.
7. Our commitment
The Company will continue to strive for effective ways of improving communication and adherence to ethical business practices and risk assessment. Feedback from all stakeholders is welcomed. The Company's policies, procedures, and verification processes are geared toward balanced, reasonable, practical, and effective approaches.
8. Approval
This statement is made under section 54 of the Modern Slavery Act 2015 and serves as the anti-slavery and human trafficking statement for the 2024 financial year. This statement has been approved by the Board of Directors, and a copy has been signed by Mr. Mark Thompson, the Group Operations Director.
