Modern Slavery Statement

LTC Healthcare is committed to conducting business responsibly and to preventing modern slavery, human trafficking, forced labour, bonded labour and other forms of exploitation within our own operations and supply chain.

Our annual turnover is below the £36 million threshold at which publication of a Modern Slavery statement is currently mandatory under section 54 of the Modern Slavery Act 2015. We have nevertheless chosen to publish this statement voluntarily because we believe businesses involved in international healthcare supply chains have a responsibility to understand and manage human-rights and labour risks.

We have a zero-tolerance approach to knowingly using or supporting forced labour, human trafficking, child labour or other forms of modern slavery.

LTC Healthcare is a UK-based specialist supplier of sexual-health and healthcare products. Our activities include the supply of our own brands, third-party products, private-label products and products supplied to public-health organisations.

Our supply chain includes manufacturers and suppliers within the UK and internationally. Because manufacturing and material sourcing can take place in different jurisdictions, we recognise that modern-slavery risks may vary according to geography, sector, employment practices and the use of subcontracted or temporary labour.

We therefore apply additional due diligence where we consider the nature or location of the supply chain creates greater potential exposure.

We expect employment within LTC Healthcare and throughout our supply chain to be freely chosen and conducted in accordance with applicable employment and human-rights legislation.

Our core expectations are that:

• forced, bonded, trafficked or involuntary prison labour must not be used;
• child labour must not be used;
• workers must not be required to surrender passports or other identity documents as a condition of employment;
• workers must not be required to pay inappropriate recruitment fees, deposits or bonds;
• workers must be free to leave employment subject to reasonable contractual notice;
• recruitment must be lawful, transparent and voluntary;
• wages, benefits and working hours must comply with applicable legal requirements;
• employment must not be used as a mechanism for discrimination, abuse, harassment or intimidation;
• workers should have access to appropriate grievance or reporting mechanisms; and
• suppliers must cooperate with reasonable ethical, labour and human-rights due diligence undertaken by LTC Healthcare.

These principles complement our wider Ethical Trading Policy and responsible-sourcing processes.

LTC Healthcare seeks to understand who manufactures the products we supply and to apply proportionate due diligence to manufacturers and material suppliers.

Our supplier-assurance approach may include:

• identifying the manufacturer and manufacturing location;
• reviewing relevant ethical-trading and human-rights policies;
• reviewing independent ethical audits where available;
• considering recruitment and employment practices;
• reviewing the use of agency, temporary or migrant labour where relevant;
• assessing identified audit findings and corrective actions;
• direct supplier discussions and site visits;
• monitoring material changes within the supply chain; and
• escalating concerns where appropriate.

Supplier risk is reviewed according to the nature of the product, manufacturing location, available independent assurance and any information that may indicate increased labour or human-rights risk.

Where a significant new manufacturer is appointed, modern-slavery and ethical-trading considerations will form part of our supplier-approval process.

Richter Rubber Technology Sdn Bhd (RRT), Malaysia, is LTC Healthcare’s principal manufacturing partner for EXS latex condoms and lubricant products.

Because RRT represents a significant overseas manufacturing relationship, LTC Healthcare applies additional ethical and labour-practice oversight.

Where LTC Healthcare identifies a potential modern-slavery or serious labour-practice concern, the issue will be assessed and investigated.

Depending upon the nature and severity of the concern, actions may include:

• requesting further evidence from the supplier;
• requiring a documented corrective-action plan;
• agreeing a responsible owner and target completion date;
• monitoring action to closure;
• undertaking additional supplier review or audit;
• escalating the matter to senior management; or
• suspending or reconsidering sourcing where a serious issue cannot be appropriately resolved.

Where there are reasonable grounds to believe that forced labour, human trafficking or another serious criminal offence may have occurred, LTC Healthcare will consider appropriate escalation to relevant authorities or specialist organisations.

Our objective is to protect affected workers and achieve appropriate remediation while ensuring serious or unresolved abuses are not tolerated within our supply chain.

Where customer contracts impose specific anti-slavery or human-rights requirements, LTC Healthcare will incorporate those requirements into its supplier-management processes as appropriate.

For example, the NHS Scotland Framework requires suppliers to conduct supply-chain due diligence, maintain accurate supply-chain records and include equivalent anti-slavery obligations within contracts with relevant direct suppliers and subcontractors.

LTC Healthcare will maintain appropriate records demonstrating the due diligence undertaken in relation to relevant suppliers and manufacturers.

Employees are encouraged to raise any concern regarding suspected unethical conduct, forced labour, human trafficking or other inappropriate labour practices.

Concerns may be raised through an employee’s normal management route or directly with senior management. Concerns raised in good faith will be treated seriously and investigated appropriately.

No employee should suffer detrimental treatment for raising a genuine concern in good faith.

Overall responsibility for our approach to modern slavery and responsible supply-chain management sits with the Directors of LTC Healthcare.

Operational responsibility for maintaining supplier due diligence and reviewing relevant ethical and modern-slavery assurance is delegated to the appropriate members of the management team.

For significant public-sector contracts, named Contract Managers will ensure that any additional contractual supply-chain requirements are incorporated into the relevant contract-management process.

LTC Healthcare recognises that modern-slavery due diligence is an ongoing process rather than a one-off supplier assessment.

We will continue to develop our approach by:

• maintaining visibility of significant first-tier manufacturers;
• reviewing independent ethical-audit evidence where available;
• continuing direct manufacturer audits and supplier engagement;
• improving documentation of supplier due diligence;
• considering modern-slavery risks when significant supply-chain changes occur;
• monitoring material corrective actions; and
• updating our policies and processes as legislation and recognised good practice develop.

This statement has been approved by the Directors of LTC Healthcare and will be reviewed at least annually, or earlier where a material change occurs within our business, supply chain, legislation or identified risk profile