Modern Slavery Policy and Statement

Painfree Potential  Modern Day Slavery Statement


Last reviewed – 24/9/20

Next review due – 24/9/21

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Painfree Potential has taken, and is continuing to take, to make sure that modern slavery or human trafficking is not taking place within our business or supply chain during the year ending 24/9/2020. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Painfree Potential has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the company or our supply chain.

About Painfree Potential

Operates in the health/wellbeing online retail sector, and has similar levels of activity throughout the year.

Painfree Potential is the UK distributor for APS Therapy machines, manufactured by a small, family-run business, APS Marketing BV, based in Holland.

Some machine parts are manufactured in China, where APS Marketing BV has a close relationship with the factory. Some are manufactured in Holland, and assembly is in Holland within a  small family business that employs less than 10 people.

In the UK, Painfree Potential contracts the services of one supervised freelance APS therapy practitioner, who is paid to teach and supervise clients remotely. All other work is carried out by the director.

Responsibilities of Management

Responsibility for ensuring the effective implementation and operation of the arrangements will rest with the Chief Executive. Directors / Managers will ensure that they and their staff operate within this policy and arrangements, and that all reasonable and practical steps are taken to avoid modern day slavery practices infiltrating the company. Each manager will ensure that:

  • all their staff are aware of the policy and the arrangements, and the reasons for the policy;
  • Concerns are dealt with properly, fairly and as quickly as possible;
  • proper records are maintained.


Human Resources / Head Office will be responsible for monitoring the operation of the policy in respect of employees and job applicants, including periodic audits.

Responsibilities of Staff

Responsibility for ensuring that the company avoids modern day slavery rests with all staff and the attitudes of staff are crucial to the successful operation of fair employment practices. In particular, all members of staff should:

  • make themselves are of, and comply with this policy and arrangements;
  • inform their manager if they become aware of any practice or instance that potentially involves exposure to modern day slavery
  • Conduct due diligence in all recruitment and contract negotiations.

Policies in relation to slavery and human trafficking

We will:

  1. Examine internal business procedures to avoid making demands of suppliers or subcontractors that might lead them to violate human rights, including children’s rights. These types of demands include insufficient or late payments, and late orders or high-pressure deadlines resulting from poor demand forecasting.
  2. Ensure that zero tolerance for modern slavery and respect for human rights, including children’s rights, are built into contracts and represented in dialogue, self-assessment, audits, training and capacity building opportunities for suppliers, subcontractors, customers, and other business partners.

Due diligence processes

Many human rights breaches, including modern slavery, are not immediately apparent. In fact, some suppliers may even go to great lengths to hide the fact that they are using slave labour.

We will:

  1. Ask all of our suppliers to provide evidence of compliance to our code of conduct by agreeing to the following statement:

“The contractor warrants that it has thoroughly investigated its labour practices and those of its direct suppliers to ensure that there is no slavery or forced labour used anywhere in its organisation or used in any of its direct suppliers’ or subcontractors’ organisation. The contractor further warrants that it has put in place all necessary processes, procedures, investigations and compliance systems to ensure that the warranties made above will continue to be the case at all times. Painfree Potential reserves the right to audit your supply chain at any time, with prior notice if it has reason to suspect that the above requirements have not been met.”

  1. not knowingly support or deal with any businesses involved in slavery or human trafficking.
  2. pay all employees at least the national minimum wage/national living wage (as appropriate, or London Living Wage for London only) currently in operation
  3. Ensure our supply chain pay all employees at least the national minimum wage/national living wage (as appropriate, or London Living Wage for London only) currently in operation
  4. Assess the physical appearance of candidates or current employees/staff at interview and/or other arranged meetings/appointments; whilst maintaining an awareness of the signs of psychological abuse (i.e. malnourishment, unkemptness, those that appear withdrawn/fearful or who wear the same clothes daily)
  5. Record details of persons who do not have, or have difficulty in producing, their own personal identification and/or other documents/records, or have to seek these from other persons;
  6. Monitor registered addresses of personnel using electronic systems to ensure employees/staff who have not declared themselves as family or marital/civil or other partners, are not residing at the same address unless a reasonable justification exists.
  7. Operate a policy whereby all employees/staff must arrange and discuss their employment/work/assignments/patterns/availability etc. directly with the company themselves, and not through a third party, unless a suitable justification exists.

Key performance indicators to measure effectiveness of steps being taken

  1. Staff turnover
  2. Staff progression
  3. Personal Development and appraisal meetings
  4. Salaries paid electronically to named bank account


The effectiveness of this policy and associated arrangements will be reviewed as part of Financial Year End under the direct supervision of the Company Chief Executive.


Signed by the Director _e signature: E.M. Olding