Modern Slavery and Human Trafficking Statement 2022

Introduction
Davis Schottlander & Davis Ltd (Schottlander) is committed to the manufacture and supply of products and services for use by medical and dental healthcare workers that meet or exceed statutory and customer requirements. Schottlander conducts its business according to the standards of good ethical, employment and environmental practice and expects its suppliers and partners to operate on the same principles. 

Responsibility
Responsibility for the preparation and publication of this statement resides with the Directors of Schottlander and is produced to support our commitment to compliance to Modern Slavery requirements and Labour Standards Assurance initiatives.

Our Business Structure and Supply Chain
We are a UK based, privately owned and managed company with a 100-year reputation for supplying quality products in a professional and ethical manner. We have a focus on long term relationships both with customers and suppliers. We supply our products to more than 40 countries around the world. 

Our supply chain is supported by central functions such as Finance, Customer Services, Human Resources and Technical departments. It includes the sourcing of both raw materials and finished goods for the medical and dental markets.

Most of our suppliers of both raw materials and finished goods are based in Western Europe and North America, while a minority are based in Southeast Asia.

Identifying Potential Risks on our Supply Chain 
Our supply chain is regularly risk assessed considering third party data on the risks of modern slavery and human trafficking, as well as the efficacy of local legislation and enforcement to prevent it, in each country from which we source raw materials and finished goods. 

The majority of our suppliers manufacture and are based in countries in Western Europe and North America, where such risks in the country as a whole are judged to be low, and, in the absence any additional risk factors, personal visits to manufacturing sites and inspection of regulatory accreditation is deemed sufficient. 

The minority of our suppliers manufacture and are based in Southeast Asia (predominantly Malaysia) where risks in the country as a whole are judged to be intermediate. For these suppliers, personal visits to manufacturing sites and inspection of regulatory accreditation are supplemented by inspection of their own social accountability systems and the commissioning of annual, accredited external audit reports to ensure continued compliance to modern slavery regulations. 

Risk Environment and Risk Mitigation
During our business activities, the potential risk of Modern Slavery arises from the following scenario:

That we procure raw materials or finished goods where there is an unethical supply chain and they are produced using modern slavery or forced labour. This risk is mitigated by:

Maintaining policies, processes, and procedures in our procurement operations, including contractual  arrangements with suppliers, that require the monitoring and enforcement of legal minimum standards and include appropriate termination clauses. 

Only using vetted and monitored suppliers who demonstrate compliance to the requirements of the Modern Slavery Act 2015. 

Maintaining on open and constructive dialogue with our suppliers in which we share our policies and requirements and work with them to ensure that they are met. 

Our Policies in Relation to Modern Slavery
We believe in the importance ensuring that our standards are being implemented throughout the businesses of our suppliers and that all relevant local legislation and international standards are complied with. Our values and the requirements of our suppliers are communicated through our own policies and procedures, including:

Communication with suppliers to ensure an understanding of the Modern Slavery Act 2015. Ensuring compliance with the Modern Slavery Act 2015 is a condition of our supplier contracts. 

Sharing and requiring annual agreement to our Ethical Policy for Suppliers that included minimum standards, adopted from the Ethical Trading Initiative (ETI) Base Code including:

• Employment is freely chosen
• Freedom of association and the right to collective bargaining are respected
• Working conditions are safe and hygienic
• Child labour shall not be used
• Living wages are paid
• Working hours are not excessive
• No discrimination is practiced
• Regular employment is provided
• No harsh or inhumane treatment is allowed

Conducting regular risk assessments and information exchanges, leading to reviews of supplier performance and on-site inspections. 

Conducting annual review of our Sustainable Procurement Plan, Ethical Policies for Suppliers, Modern Slavery Statement and Modern Slavery Policy.

Internal Training and Awareness
We have a policy of continuous improvement leading to a rolling program of internal training for all relevant personnel in the business, including all of those within our Purchasing and HR teams, to ensure a high level of understanding of the risks of modern slavery and human trafficking. 

This includes training on the basic principles of the Modern Slavery Act 2015, its relevance to their role, our internal policies, and the legal, moral and reputational reasons behind them. It also covers how employees can identify and prevent slavery and human trafficking, and how to flag up potential slavery or human trafficking issues to the relevant parties, including immediately escalating concerns to senior management. 

Key achievements in 2022
Maintained our level 2 LSAS (Labour Standards Assurance) compliance. This system, developed by NHS Supply Chain, Department of Health and other stakeholders, contains requirements for an organisation to design a management system that reduces the potential for labour standards abuses to go undetected and unresolved.

Updated our Sustainable Procurement Plan, Ethical Policies for Suppliers, Modern Slavery Statement and Modern Slavery Policy.

Continued the use of third-party audits suppliers in intermediate risk jurisdictions, using the Smeta (Sedex Members Ethical Trade Audit) methodology. 

Continued to engage with our suppliers to share concerns and ensure their formal and evidenced agreement to polices safeguarding against modern slavery.

Continued to ensure that our compliance and monitoring systems are sufficiently pro-active and robust to identify and report potential  concerns relating to modern slavery and human trafficking

Continued to build specific compliance conditions within our contracts and legal agreements

Engaged Schottlander’s management team in wider ‘Compliance’ issues. 

2023 Objectives 
We remain committed to ensuring that our own business and our supply chain is free from Modern Slavery and Human Trafficking. 

Although we see no risk of modern slavery or human trafficking within our own organisation, we are reviewing the wording of our HR policies and our recruitment processes to reinforce our zero-tolerance message on these issues.  

Following a review of the effectiveness of the steps we have taken to ensure there is no modern slavery or human trafficking in our supply chains, we intend to take the following further steps in 2023: 

• Review our supplier due diligence processes.
• Ensure that training is updated, and all relevant staff continue to be made aware of the principles of the Modern Slavery Act 2015 and its relevance to their role.
• Strengthen internal reporting mechanisms to ensure that colleagues are aware of their means of reporting concerns directly to senior management. 
• Continue our schedule of in person visits to all suppliers within intermediate risk countries, that were suspended during the pandemic. 

This statement covers the period of our financial year ending 31^st December 2022 and is made pursuant to Section 54 of the Modern Slavery Act 2015. 

Brian Schottlander, Managing Director.
6th August 2023.