TCD Medical is a rapidly growing distribution company based in Manchester England
specialising in homecare and pharma transport.
We take our brand very seriously because our identity is based on maintaining a customer
focussed approach. We want to grow without compromising on service but also all the time
committing to our corporate social responsibility.
TCD Medical believe transparency is the best way we can ensure the public that we are
doing our best as an ethical corporate citizen. We have published our annual statement for
slavery and human trafficking, made in compliance with section 54 of the Modern Slavery.
Act 2015, in which we explain how slavery and human trafficking can affect our business
and the steps we are taking in the fight against it.
We have a small but dedicated workforce and our focus is on providing services to
companies based in the UK. This allows us to focus our oversight and influence on one
geographic region.
We have around 15 people within our organisation and many more through the supply
chain. Where possible, we engage suppliers who have relationships with existing suppliers
so that we can contain our supplier network and improve consistency in ethical practices
throughout the supply chain.
Building on our existing corporate social resonsibility policy and our commitment to the
Ethical Trading Initiative, we have embraced the requirement to publish an annual slavery
and human trafficking statement. This will allow us to share our efforts against slavery and
human trafficking and improve and measure our success each financial year.
This year we have developed our Slavery and Human Trafficking Policy, we updated our
Supplier Code of Conduct. It sets out clear objectives for 1, 3 and 5 year slavery and
human trafficking plans around the following themes:
• Relationships: Strengthening our supplier engagement process
• Feedback: Establishing grievance mechanisms and channels for individual worker
feedback
• Knowledge: Improving our knowledge base by collecting relevant data and improving
product traceability
• Measurable change: Developing verifiable KPIs to measure progress
• Supplier collaboration: Encouraging suppliers to collaborate to address slavery and
human trafficking issues
• Incentivisation: Developing mechanisms to incentivise employees and suppliers to
address slavery and human trafficking and improve labour standards
• Accountability: Establishing a framework for organisation accountability to allow for
raising issues, making suggestions, voicing grievances and reporting slavery and human
traffickin.
We understand that our biggest exposure to Modern Slavery is in our supply chains. As a
relatively young company we are able to check all our new suppliers and we ensure they
are subject to due diligence checks in the form of ethical/compliance audits. Such audits
are also regularly conducted for existing suppliers and factories/sites. These audits assess
compliance with the Global Sourcing Principles and are, amongst other things, intended to
identify any Modern Slavery practices. If issues are identified, appropriate investigative
and remedial actions will be taken.
We will identify the extent of any slavery and human trafficking in our supply chains by
collaborating with 2 of our suppliers to develop an improvement plan to address new and
previously identified slavery and human trafficking issues and by conducting an annual
review questionnaire for existing suppliers to understand suppliers’ self-assessment of
slavery and human trafficking issues, allowing us to better identify slavery and human
trafficking issues as they develop over time and to collect supplier-provided data to track
improvement in suppliers’ attitudes.
In order to assess the effectiveness of our modern slavery measures we will be reviewing
the staff training levels and the number of slavery incidents reported in the supply chain
A key part of our slavery and human trafficking strategy is to promote cultural change
through training. We aim to deliver online training modules on modern slavery to all staff
this year TCD will assess all suppliers before contracting and as part of tender exercises to
establish adherence to local and national laws, freedom of workers to terminate
employment, feedom of movement, freedom of association.
Suppliers must prohibit any threat of violence, harrassment and initimidation, prohibut the use of worker-paid
recruitment fees, prohibits compulsory overtime, prohibits child labour, prohibits
discrimination, prohibits confisaction of workers original identification documents, and
ensures suppliers provides access to remedy, compensate victims of modern slavery
TCD will ensure that training encorporates shows members of staff to look out for the signs
of Modern Slavery when searching for suppliers. TCD must not unintentionally contribute
to Modern Slavery by ignoring key indicators that an organisation may subject their
employees to poor recruitment practices, poor working conditions and low pay for workers
These conditions include: aggressive pricing that does not consider sustainable production
costs, short lead times, late high-volume orders, inaccurate forecasting, late or extended
payments, withdrawing from contracts last minute, unfair penalties for not meeting orders
despite last minute changes, accuracy of technical specifications
TCD will consider modern slavery issues at different stages of the procurement process to
help reduce risks the business. For example, during the tender stage, TCD will factor in
labour costs in to their procurement and consider whether the price they are paying for
goods and services are so low that the supplier (or the suppliers) are likely to be exploiting
workers
Where TCD is alerted that one of their suppliers/customer is causing modern slavery, and
is cooperating with authorities, actively implementing corrective actions and is not found to
be complicit, TCD will not immediately delist or suspend trade with that supplier because
of that specific incident however will create a service level agreement to formally give a
specific time frame and with a specific response.
Signed
Christopher Sharp
Operations Manager
TCD Medical