Modern Slavery Policies
Phoenix Medical Modern Slavery Policy V1.1
1. Introduction
Phoenix Medical is committed to ensuring that modern slavery and human trafficking are not taking place
within our business operations or supply chains. This policy outlines our approach to preventing and
addressing any risks related to modern slavery in compliance with the Modern Slavery Act 2015.
2. Purpose
The purpose of this policy is to:
• Ensure that all employees, suppliers, and stakeholders understand our commitment to preventing
modern slavery.
• Outline the steps we are taking to identify, mitigate, and address any risks related to modern
slavery.
• Encourage transparency within our operations and supply chains.
3. Scope
This policy applies to all employees, contractors, suppliers, and any other parties working with or on behalf
of Phoenix Medical.
4. Our Commitment
Phoenix Medical is committed to:
• Operating with integrity and ethical standards.
• Complying with all applicable laws and regulations regarding modern slavery and human trafficking.
• Identifying and assessing potential risks in our supply chains and business operations.
• Taking appropriate action if modern slavery is identified, including reporting to relevant authorities.
• Continuously improving our practices to combat modern slavery
5. Supply Chain Due Diligence
Phoenix Medical undertakes a robust due diligence process that includes:
• Supplier Assessments: Regular assessments of our suppliers to ensure they are compliant with the
Modern Slavery Act 2015.
• Risk Analysis: Identifying areas within our supply chains that may be vulnerable to modern slavery
and implementing appropriate measures to mitigate these risks.
• Supplier Contracts: Ensuring that contracts with suppliers include obligations to comply with our
anti-slavery policies and to act in accordance with applicable laws.
6. Supplier Conduct
When dealing with suppliers, we avoid:
• Aggressive pricing that doesn’t consider production costs.
• Short lead times.
• Late high-volume orders.
• Inaccurate forecasting.
• Late or extended payments.
• Late withdrawal from contracts.
• Issuing unfair penalties.
• Supplying inaccurate technical specifications.
7. Training and Awareness
We are committed to educating and raising awareness among our employees and suppliers by:
• Providing regular training on modern slavery and human trafficking.
• Ensuring that all employees understand the signs of modern slavery and how to report concerns.
• Engaging with suppliers and partners to promote awareness of modern slavery risks
8. Reporting and Whistleblowing
Phoenix Medical encourages all employees, suppliers, and stakeholders to report any concerns related to
modern slavery. We will:
• Provide a confidential and secure whistleblowing mechanism for reporting concerns.
• Ensure that all reports are taken seriously, investigated promptly, and treated with confidentiality.
• Protect whistleblowers from any form of retaliation.
9. Governance and Accountability
The Management at Phoenix Medical holds overall responsibility for ensuring compliance with this policy.
Specific responsibilities include:
• Modern Slavery Compliance Officer: Appointing a dedicated officer to oversee the implementation
of this policy.
• Annual Review: Reviewing the policy annually to ensure its effectiveness and making necessary
adjustments.
10. Monitoring and Review
Phoenix Medical will:
• Regularly monitor and audit our supply chains to ensure compliance with this policy.
• Review and update this policy as necessary to reflect any changes in law or company operations.
• Report on our progress in combating modern slavery in our annual Modern Slavery Statement.
11. Conclusion
Phoenix Medical is dedicated to playing its part in the global fight against modern slavery. We expect all
employees, suppliers, and partners to share this commitment and to actively participate in preventing and
addressing modern slavery in all forms.
Approval & Implementation:
This policy has been approved by the Managing Director and is effective from 05/02/2024. It will be
reviewed and updated annually or as required.
At Phoenix Medical Ltd, we uphold principles of honesty and integrity in all our international business dealings. We hold a deep respect for human rights and ensure that individuals within our supply chain are treated with dignity. Recognising modern slavery as a global issue affecting all economies, industries, and sectors, we are committed to addressing it comprehensively. Our approach involves identifying areas and methods where modern slavery persists, and taking targeted actions to either eliminate instances or effectively manage associated risks.
Phoenix Medical Ltd Modern Slavery and Human Trafficking Statement V.2024/2025
1. Organisational Structure and Supply Chains
Phoenix Medical Ltd specialises in innovating and advocating for high standards in medical devices and plant-based medicine, as well as various natural health products. We cultivate partnerships throughout the entire supplier chain, spanning Asia, Europe, and North America.
2. Policies in relation to Modern Slavery and Human Trafficking
Phoenix Medical Ltd fully supports the government’s objectives to eradicate Modern Slavery and human trafficking and recognises the significant role we must play in responsible prevention, combating its existence, and supporting victims. This includes being strongly committed to ensuring our supply chains and business activities are free from ethical and labour standard abuses. Company policy is to follow guidance set out in the government’s Modern Slavery Assessment Tool (MSAT), working towards improving our score and assessing annually to remain vigilant.
3. Due diligence process
Our supplier relationships are founded on a basis of earned trust and evidence of good procedure. Our procurement policy involves assessing supplier facilities and working conditions prior to engaging financially. Suppliers are required to assess and report their internal management techniques of such risks ensuring they meet a satisfactory threshold.
4. Risk assessment and Management
As stated, we assess our current practices against UK government standards using the MSAT, which provides measurable feedback on our performance and identifies areas for improvement. Our updated supplier agreements will include dedicated sections outlining ethical manufacturing requirements, along with conducting audits in identified high-risk areas of the supply chain.
5. Effectiveness
In order to enhance our effectiveness in the upcoming year, we commit to the following actions:
• Continuing to refine our strategy for eradicating modern slavery across the Phoenix Medical Ltd supply chain, including improving risk mapping and management from key suppliers.
• Increasing the level of scrutiny applied to suppliers during our vetting process to safeguard our existing high standards.
• Heightening auditing requirements for suppliers identified as being at high risk of modern slavery.
• Conducting workshops and webinars to raise awareness of risks among our independent teams.
6. Training
We allocate appropriate resources to training to ensure that team members engaging with suppliers can readily identify and respond to incidents of modern slavery. We collaborate closely with our suppliers to ensure they are also cognisant of these risks and can implement their own training policies accordingly.
Phoenix Medical
Phoenix Medical is committed to upholding the highest standards of Chinese medicine practice across the UK and Europe. We adhere to strict guidelines and regulations, supplying our products exclusively to registered healthcare practitioners.