This statement sets out PDSA’s commitment, and steps put in place, to preventing slavery and human trafficking in its organisation and within its supply chains. The organisation acknowledges responsibility to comply with all principles of the Modern Slavery Act 2015 (MSA). This statement relates to the financial year 1 January 2017 to 31 December 2017.
PDSA have a zero tolerance approach to human trafficking and slavery. The MSA applies not only to the organisation’s own internal business but also to external suppliers. Due diligence is carried out within the organisation and also within the supply chains to ensure the organisation does not knowingly engage with external parties involved with slavery or human trafficking.
Purchasing Policy and Processes
Nearly all goods and services are purchased from UK based suppliers, our pre-qualification selection process requires that all potential suppliers invited to compete for business provide details not only of their own internal policies and procedures, including ethical policies, but also that they divulge what processes they undertake when selecting and managing their suppliers. Checks are undertaken through a variety of measures throughout the selection process and life of the contract. These include:-
- The completion of a pre-qualification questionnaire (PQQ); provision of the PDSA Supply Policy and Ethical statement – when prospective suppliers are invited to compete;
- New supplier registration forms require the requester to review that a potential supplier is compliant with the MSA 2015
- Contracts made on our terms contain clauses relating to the suppliers policies and adherence to our ethical requirements.
The detail that is undertaken will be determined by the actual goods/services we are buying and the expected potential risk of unethical practices, such as child labour, very poor working conditions, etc. either known to us from experience of the industry or established through information provided by potential suppliers at PQQ or vendor registration stages.
Supply Chains in PDSA
PDSA is comprised of a number of supply chains based on its diverse range of activities that support the core veterinary service. The organisation therefore, recognises the need to have a central Contracts and Procurement function that develop, disseminate and monitor compliance of the purchasing policy and the processes followed in supplier selection, which includes review of ethical sourcing practices.
PDSA purchases a variety of goods and services, the range includes veterinary medicines and equipment; giftware for sale in its shops; staff uniforms, branded items for fundraising events, advertising space and recruitment agencies, printed matter and other marketing materials, as well as all of the services to support its employees and infrastructure.
Mitigation of risk in the supply chain
The parts of the supply chain most susceptible to risk of human trafficking and slavery would be the purchase of any goods that we know will be sourced from non UK based companies and particularly if they are located within non-EU countries. Our supplier contracts will usually be from UK based sources; we understand the need to have visibility of their suppliers and full compliance with The MSA 2015. Identified risk purchases include our polyethylene carriers and collection sacks, some giftware sold in our stores, some of our promotional goods purchased for giveaways and some of our printed matter.
The suppliers of these items will go through the usual due diligence but in addition we will also undertake some or all of the following: -
- Ask to see all of the internal policies of the company
- Ask to understand the manner in which they are monitored and frequency
- Ask to be introduced to the Purchasing Manager and be physically shown the policy and processes used when selecting their suppliers and how they are monitored
- Ask for details on site visits carried out to the manufacturing facilities and audits undertaken
- Ask for the names and addresses of the suppliers to be used for our account
- Ask to see their suppliers documented policies around ethical practices and H&S
- Research these suppliers to identify if they have any history of unethical practices
- Have detailed clauses in our contracts that cover off ethical supplier selection, and the requirement for ongoing monitoring.
- Ensure that the suppliers evidence details around monitoring of manufacturers in formal reviews.
Page last updated: 18th August 2017