Disposable Medical Instruments Ltd
Labour Standards Assurance Policy
Disposable Medical Instruments (DMI) manufactures and supplies a range of medical devices throughout the UK, Europe, Asia, Canada and Australia. These products include: - single instruments (forceps, scissors, speculum, ENT, podiatry). We have our own class 7 clean room and to this end we can and are certificated to do third party packing and design of custom packs. We also have an in-house Eto gas sterilisation machine (sterilising process for medical industries) certified to 11b classification
As a company, the senior management are fully informed of the need for a Labour Standards Assurance Policy and the obligation to our employees, customer, and supplies with in the sector we operate. For this reason we are making this policy public knowledge.
Scope of the Policy
DMI has set this policy to cover its supply to the NHS via the Framework Agreement:-
Surgical Instruments (OJEU reference 2012/S 75-122614) Offer reference FAG 445
Scale of the Policy
DMI is committed to implement this policy in line with EU law as a SME
Policy Review and Improvements
DMI will review this policy periodical in line with LSAS policy and legislation changes, any requirements needed to ensure that we have a suitable and effective policy will be adhered to.
Application of Labour Standards, Application of the Code & Laws & Ethical Standards
- Minimum Labour Standards - are derived from the Ethical Trading Initiative (ETI) Base Code, which in turn is founded on the conventions of the International Labour Organisation (ILO)
- Suppliers – shall comply with all laws applicable to its business locally and nationally. The supply should adhere to the principles of the United Nations’ Global Impact, UN Declaration of Human Rights as well as the 1998 International Labour Organisation’s “Declaration of Fundamental Principles and Rights at Work” in accordance with National law and practice.
The supplier shall ensure conformance to all laws applicable in their nation and locality.
Suppliers – are expected to have noted the requirements of the Code and to have established similar arrangements to provide evidence that they are working towards the requirements.
- Provisions of Law - where this Code and provisions of law address the same subject, the provision which affords the greater protection shall be applied.
- Complying with the Code – companies applying this Code are expected to comply with national, local and other applicable laws.
- Workers – are defined as those employed on a temporary basis or permanent basis, as well as workers that are employed either directly or indirectly
Minimum Labour Standard
DMI has identified the following reasons to establish a comprehensive system of Minimum Labour Standards to guide its business operations.
- Ethical Responsibilities – the company accepts its obligation to its employees, customers and suppliers with in the sector we work to operate in an ethical manner.
- Risk of Supply – DMIhas identified that labour standards abuses in supply chain can pose a risk of supply. Any supply chain partners of DMI committing abuses face legal enforcement action which could damage business and obstruct continue of supply.
- Damage to the company’s reputation due to adverse publicity- discovery of labour standards abuse presents a reputation and structural risk (1) Turnover- customers choose to purchase supplies and services from other sources. (2) staff retention and recruitment may be affected as people choose not to work for a company associated with any labour standards abuses; this could also lead to low morale in the work place and difficulty in recruitment (3) loss of trust with customers and suppliers within the wider society.
Objectives and Targets
- Labour Standards Assurance – Questionnaires: DMI will request LSAS Questionnaires to be completed for new suppliers, and will revisit and request updated questionnaires at 6-12 month intervals. Questionnaires are to be completed by Suppliers within 14 days (from date Questionnaire sent).
- Non-Conformance –all NCR’s to initially be investigated by Finance & Compliance Manager. Reporting findings to Supplier within 14 days of Non-Conformance being raised.
DMI will continue to review and monitor supplier remedial action over a 12 month period from date NCR reported.
If such supplier does not conform with standards required, and does not respond within the 14 day period, the matter will be escalated to the Operations Director to take appropriate action.
- Labour Standards Assurance System (LSAS)– achieving Level 4 (highest level required by NHS Supply Chain) – The Finance & Compliance Manager will take action from October 2015 to collaborate and share resources with other suppliers/organisations that are currently working towards achieving Level 2 (minimum standard) – Level 4 LSAS. The Finance & Compliance Manager will have communicated up-to-date Labour Standards Assurance Policy, LSAS Questionnaires, and will set up training sessions, meetings, and presentations with these suppliers (timescale by April 2016).
- The company recognises that our suppliers may face challenges in today’s globalised marketplace. We aim to work with our suppliers openly and honestly. Where concerns about human rights, labour, environment or ethical issues are identified, we will work with them to make improvements to the issues arising.
- For NHS Supply Chain are recorded and monitored and dealt with immediately as they arise. For manufacturer non- conformances (incorporating damaged instruments or instruments that are faulty), the Operations Director will contact the supplier to discuss remedial action
- Quality of Goods and services – DMI recognise that there is typically a link between labour standards and poor quality of goods and services. It is in the interest of DMI to ensure that its suppliers reach the minimum labour standards at all times.
Procedure for Non-conformance
If a Non-Conformance on any of our suppliers is reported/documented during the 6—12 month period, DMI will take remedial action by carrying out a risk assessment, and reporting the findings to the supplier with 14 days of the Non-Conformance being raised.
Dependant on the information supplied for any non-conformance, DMI can request the supplier to supply satisfactory supported and signed evidence that they meet minimum Labour Standards requirements, and DMI will continue to monitor and request any other evidence covering a 12-month period from the date of the NCR.
If the supplier does not supply satisfactory evidence/information at any stage during the 12-month period, the matter will be referred to the Operations Director, Yvonne Valentine to escalate the matter, with the potential of any supplier being withdrawn from DMI supplier database. The Operations Director, will notify the Finance & Compliance Manager and NHS Supply of any fundamental changes and report any NCR’s as appropriate.
A risk assessment is carried, and if any non-conformance is reported within a 12 month period as a result of a status review, supplier appraisal, supplier audit, third party audit, internal audit, external audit, whistleblowers or other means of communication (Public or Media), non conformances will be categorised as follows:-
Low risk – 0 < 2 Excellent – performing well, but allows for improvement
Medium risk - 3 < 5 continual improvement required
High risk – 5 < - Labour Standards Status Review, remedial action plan (CAR) and monitor over 12 month period
Disposable Medical Instruments Limited conducts its business with high standards of integrity and honesty and expects the same standards from all employees, suppliers and contractors.
All employees, suppliers’, contractors should report any concerns or suspicions about any wrongdoing or malpractice, and be assured that the information received will be treated seriously, and where possible, confidentially.
What to report:
- A Criminal offence
- Failure to comply with a legal obligation
- A danger of health and safety of an individual
- Inappropriate relationships with suppliers
- False accounting or reporting irregularities
- A delivery concealment of any of the above matters
- Information/evidence for reporting of UK and overseas suppliers not adhering to Minimum Labour Standards /ILO Conventions
You should telephone the line provided for suppliers’ employees and contractors to:
- Operations Director – Yvonne Valentine, telephone 0845 301 2007
Once a concern or incident has been reported, DMI will make preliminary enquiries and decide if further investigation is needed. If so DMI will decided whether this should be conducted internally or whether the matter should be referred externally. Where possible, DMI will advise of the outcome of any investigations.
Any supplier, supplier employee or contractor who does report their concerns will not be victims or treated less favourable in anyway as a result.
Deliverable raising false or malicious allegations is not acceptable and will be viewed extremely seriously by DMI.
Disposable Medical instruments have referred to the following resource documents:-
Social Accountability International SA8000
UN’s Universal Declaration of Human Rights
ETI Base Code
The Finance and Compliance Manager is determined as the author of the Labour Standards Assurance System (with supported evidence provided including:
Online sources, media material, suppliers, NHS Supply Chain, ETI, ILO, NATLEX, NORMLEX, BMA (British Medical Association), GRI (Global Reporting Initiative) Verite, Pakistan Council for Social Welfare & Human Rights, Rose Human Rights Welfare Organisation Pakistan, Federation of Workers Pakistan, Punjab.gov.pk, The Surgical Instrument Manufacturers Association of Pakistan, Trade Unions (Pakistan), Stakeholders and other interested parties.
Minimum Labour Standards in UK:-
- Child Labour – DMI does not engage in or support the use of child labour. If DMI engages any young workers (Work Experience) it will ensure that a suitable risk assessment is carried out, and that any young person is not exposed to any dangerous conditions, or not work more than an 8 hour day.
- Forced or Compulsory Labour- DMI shall not engage in or support the use of forced or compulsory labour, or bonded or involuntary prison labour. Employees are free to leave upon reasonable notice.
- Freedom of Association and Collective Bargaining – workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
- Health & Safety – DMI shall provide a safe and healthy workplace environment and shall take effective steps to prevent potential accidents and injury to employee’s health by minimizing the risk to its employees. All employees will receive safety and job training during their employment. Employees will have access to clean toilet facilities and drinking water. The health and safety responsibilities of DMI have been assigned to the Operations Director.
- Training – Workers shall received regular and recorded health and safety training, and new employees will receive such training.
Employees will receive regular training aligned with their respective occupation of employment (as and when necessary). All training will be documented, and reference made on staff personnel files.
- Environmental – DMI is committed to protecting the environment both through our own actions and also by working with our suppliers. We will continue to focus on delivery high standards of service and quality of goods to our customers. We will comply with all regulatory and legislative requirements to protect the environment.
- Discrimination – DMI will not engage or support any form of discrimination in its employing of staff, salary, training, promotion, termination or retirement based on race or national or social origin, caste , religion, gender , sexual preference, political affiliations, age or other circumstance that could be classed as discrimination.
- Disciplinary Practices – DMI will treat all employees with dignity and respect. DMI shall not or tolerate the use of corporal punishment, mental or physical bullying or verbal abuse of personnel. No cruel or inhumane treatment is allowed.
- Working Hours – DMI shall comply with relevant laws and labour standards on working hours and holiday entitlement. DMI’s working hours do not exceed 48hours per week and overtime hours do not exceed 12 hours per week. DMI ensure that all employees have the legal right to be employed in the UK.
- Remuneration- DMI shall comply with national laws and regulations relating to wages and benefits. All work associated activities are carried out on the basis of a recognised employment relationship established according to national law and practice.
Commitment to Continual Improvement
DMI is committed to ensuring the achievement and improvement in all areas of its business.
Our approach to continuous improvement will be underpinned by providing a high quality service, value for money and maintaining and monitoring performance, whilst administering continual improvements throughout the company.
This Policy will be subject to updates and amendments, as and when necessary. For internal measures the Policy will be reviewed at 6-monthly intervals.
Disposable Medical instruments Ltd is also committed to:-
- To be compliant with other relevant legal requirements for our Notifiable body
- Ensure that key contractors , sub contractors and suppliers are aware of this policy
- Make available time and resource for the implementation of this policy
- Ensuring that our suppliers, in particular overseas suppliers, adopt labour practices including a fair and honest approach to their employees and anyone whom they trade with
- DMI recognises the importance of corporate responsibility towards sustainable objectives and of maintaining high standards of social, ethical and environmental conduct
- DMI has built in contingency plans for Business Continuity – these are reviewed on a 6-12 month basis
- DMI is continually building in capacity for carbon reduction, enforcing recycling processes (as far as possible) and managing the amount of waste that the company produces
- DMI are innovative with their product design and can deal with bespoke customer requirements. Therefore allowing the customer to be provided with their specific requirements, thus eliminating wastage, whilst maintaining an affordable and quality product
We will make the policy public via our website - www.disposablemedicalinstruments.co.uk and be communicated to DMI’s employees and all contractors, sub contractors and suppliers.