Since the publication of our last Modern Slavery Statement in September 2024, SurgEase Innovations Ltd has implemented the following key measures to strengthen our commitment to preventing modern slavery and human trafficking:
• Introduced mandatory annual training for all employees, with role-specific modules for procurement, compliance, and QA/RA teams.
• Ensured that team members closely involved with supply chain management complete a UK Government–recommended accredited course on tackling modern slavery in supply chains.
• Adopted and issued a comprehensive Supplier Code of Conduct and Supplier Compliance Agreement, requiring Tier 1 suppliers to comply with our standards, agree to audits, and cascade requirements through their own supply chains.
• Introduced a formal Escalation & Remediation Policy outlining steps to address any identified breaches or forced labour indicators.
• Implemented a Horizon Scanning Register to proactively monitor public reports, news, and relevant databases for any breaches or risks related to our suppliers.
SurgEase Innovations Ltd remains firmly committed to preventing acts of modern slavery and human trafficking within both our business operations and our supply chain. This statement is made in accordance with Section 54 of the UK Modern Slavery Act 2015 and sets out the actions we have taken during the financial year ending 31 December 2024 to prevent slavery and human trafficking in all areas of our operations and supply chain.
SurgEase Innovations Ltd operates in the medical technology sector in the United Kingdom, with a global network of suppliers and partners. Our primary suppliers are subject to rigorous selection processes to ensure compliance with our values and legal obligations. We work with both UK-based and overseas suppliers, including Tier 1 suppliers in China, under formal contracts that reference compliance with our Supplier Code of Conduct.
Our approach to tackling modern slavery is embedded within our corporate governance framework and supported by the following key policies:
• Supplier Compliance Agreement
• Escalation & Remediation Policy
• Horizon Scanning Register
These documents collectively set clear expectations for ethical conduct, prohibit forced labour, and outline our monitoring and enforcement processes.
We conduct thorough due diligence on all new suppliers and perform ongoing monitoring of existing suppliers. Tier 1 suppliers are contractually required to adhere to our Supplier Code of Conduct, agree to both announced and unannounced audits, and cascade our standards throughout their own supply chains. Any breach may result in termination of the business
Modern slavery awareness training is mandatory for all employees. Role-specific modules are provided for procurement, compliance, and QA/RA teams, and these teams are also required to complete a UK Government–recommended accredited training course on tackling modern slavery in supply chains.
We maintain a Horizon Scanning Register to monitor for any published breaches, legal cases, or credible reports related to our suppliers. This process is conducted quarterly and covers sources such as government publications, reputable NGO reports, specialist trade press, and industry compliance databases.
If any indicators of forced labour or breaches of human rights are identified, whether through audits, whistleblowing, or horizon scanning, our Escalation & Remediation Policy sets out the steps for investigation, corrective action, and, where necessary, termination of supplier relationships.
Some of the materials used in our products may contain tantalum, tin, tungsten, and gold, which are commonly referred to as ‘conflict minerals’ due to their association with armed conflict in certain regions of central Africa. These minerals are often mined under conditions of forced labour or modern slavery. SurgEase Innovations Ltd is committed to maintaining a conflict-free supply chain and actively monitors and assesses our suppliers to ensure that these materials are sourced ethically. We recognise that conflict minerals can also bring an increased risk of modern slavery, and we are committed to ensuring that our supply chain is free from such risks. In doing so, we expect all of our suppliers to comply with our policies on conflict minerals, and we conduct due diligence on our supply chain to address these issues and offer advice and training when needed.
SurgEase Innovations Ltd performs thorough and annual due diligence on third-party suppliers and partners to assess their suitability and ensure compliance with all relevant legislation, including the Modern Slavery Act 2015. We are committed to expanding these procedures to address the specific risks associated with modern slavery and human trafficking in our supply chain.
Our supply chain primarily involves regulated sectors, and we source the majority of our goods and services from suppliers operating in countries with stringent compliance regulations. Based on our assessment, the risk of modern slavery within our supply chain is low; however, we remain vigilant and take immediate action if any evidence of non-compliance is discovered.
We are committed to continuous improvement in our approach to preventing modern slavery and human trafficking. We regularly review our policies, training, and monitoring processes to ensure they remain effective and aligned with best practice.
SurgEase Innovations Ltd
Burlington House, 1 York Road, Maidenhead, SL6 1SQ, UK
Phone: +44 (0)1234 567890
