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:
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:
Policies in relation to slavery and human trafficking
We will:
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:
“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.”
Key performance indicators to measure effectiveness of steps being taken
Review
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
Date:24/9/20