The Modern Slavery Act 2015 requires those entities carrying on a business or part of a business in the UK, supplying goods or services, and having an annual turnover of £36 million or more to disclose information regarding the steps they have taken to eradicate slavery and human trafficking from their supply chain as well as within their own organisation during the previous financial year.
Since our last statement, Thriva’s business activities have not changed considerably. We have continued to work hard to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain.
This is our third modern slavery statement which outlines what measures we have taken in the last year and what actions we will take this year to identify and mitigate modern slavery risks throughout our supply chain and operations.
All our tier 1 suppliers are based in the UK and we have contractual terms to combat modern slavery. Our principal suppliers are regulated manufacturers and distributors of medical devices and pharmaceutical products or services.
We have strengthened our supplier due diligence and onboarding processes for new supplier contracts and contract renewals and carry out annual audits on suppliers’ processes and policies.
In the past year we sourced materials from suppliers based in countries that may be more vulnerable to human rights abuses than others. We have updated our procurement strategy to take into account a country’s vulnerability score of modern slavery when making sourcing decisions.
We are creating greater visibility over our sub-tier suppliers. To aid with this, we now have dedicated procurement staff with accountability for ethical sourcing and modern slavery is considered when making purchasing decisions.
We are continuously reviewing and updating our policies to ensure that no modern slavery or human trafficking exist in our business and supply chains.
Our policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
In 2023, we broadened our procedures and systems to identify and mitigate risks. These procedures and systems are monitored and continuously updated for improved robustness:
We have a risk register and risk committee for the purpose of monitoring risks to our business, including risks relating to modern slavery and human trafficking in our supply chain.
To measure our effectiveness against slavery and human trafficking in any part of our business or supply chain, we have the following key performance indicators for 2024:
| Objective | Measureable | |
|---|---|---|
| KPI 1 | Engage with all tier 1 suppliers and conduct audits on tier 2 suppliers to start mapping visibility across sub tier suppliers | 25% of tier 2 suppliers audited |
| KPI 2 | Audit and risk assess all tier 1 suppliers | 100% of tier 1 suppliers audited and assessed |
| KPI 3 | Include anti-slavery clauses in all supplier contracts | 100% contracts include anti-slavery-clauses |
| KPI 4 | All procurement staff to complete anti-slavery training | 100% of supply chain staff trained |
| KPI 5 | Any occurrence of modern slavery remediated | 0% modern slavery and labour exploitation in the supply chain or business |
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2023. It was approved by the board on 14/03/2024.