Modern Slavery Statement

Modern Slavery Statement

This statement has been approved by the Board of Directors. It covers the activities of Bullen Healthcare Group Ltd.

a. Our structure, business and supply chains

Bullen Healthcare is a 4th generation family owned business that was established in 1858 and during that time has become one of the UK’s leading home delivery companies for Stoma, Urology and Woundcare products.

We provide a fully bespoke and personalised home delivery service for all of our customers, supplying an extensive array of Stoma products listed within the NHS Drug Tariff.

Bullen Healthcare employs around 150 people across mainland Britain, with slightly over half working from the Head Office in Liverpool. Products are procured from over 100 suppliers and delivered to a central warehouse in Liverpool. Most products are manufactured in the EU.

b. Policies in relation to slavery and human trafficking

We use Public Health England’s definition of Modern Slavery:

“Modern slavery is defined as the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. It is a crime under the Modern Slavery Act 2015 and includes holding a person in a position of slavery, servitude forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon after 14.”

We have a number of policies that have been written to ensure the protection of workers’ rights. The content of these policies is communicated to the workforce through the Employee Handbook which makes it clear that we do not tolerate any instances of Modern Slavery or Human Trafficking in our business or our supply chain.

Our commitments in this area are stated in our Equality Policy. Our Employee Handbook states that we operate an open door policy in the business and encourage employees to raise any concerns they have informally.

Bullen Healthcare expects any staff who become aware of a potential breach of these commitments to raise it by following the Reporting and Management of Incidents Policy, Whistleblowing Policy and Safeguarding Vulnerable Adults Policy.

c. Due diligence processes in relation to our business and supply chains

We audit the application of our HR policies in relation to our own staff and provide assurance to the Board that we are complaint with, and go beyond, all relevant legislation.

We check the Modern Slavery Statements of our key suppliers who account for the majority of products supplied to the business. Wherever an instance of potential non-compliance is identified with a supplier, our policy is to  seek dialogue with that supplier to identify the exact details of the issue. We expect the supplier to provide assurance that either the issue does not exist or that appropriate measures have taken been taken to resolve it.

Our expectations and zero-tolerance approach are made clear to our supply chain. We expect all of our suppliers, employees and partners to demonstrate a similar commitment and engage with our Procurement Team. If a supplier chooses to disengage or obstruct our efforts relating to the Modern Slavery Act 2015 our Procurement Manager is empowered to terminate the relationship.

We conduct an annual employee survey to assess how our staff are feeling about the business, their work and the leadership. We use the intelligence we gain from this to improve the well-being and engagement of our staff, as well as highlighting any risks described by staff in relation to their working conditions or mental health.

d. Assessing and managing the risk of slavery and human trafficking taking place

Our suppliers have provided assurances that they are compliant with all aspects of the Modern Slavery Act 2015. We have assessed the risk of non-compliance with these suppliers as very low.

Any risks are more likely to occur in our suppliers’ supply chains. Our suppliers provide assurance through their Modern Slavery Statements that they are taking the necessary steps to assess and manage those risks. We have assessed this risk as medium and manage it by auditing our suppliers’ statements every financial year and seeking further assurances as required.

e. Effectiveness and Measurement

We are assured that our key suppliers have taken effective action to improve the performance of their suppliers and have terminated contracts with their suppliers who have failed to address non-compliance.

For the year ahead, we plan to consider what KPIs would add the most assurance and robustness to our audit, and report against those in the statement at the end of this financial year.

f. Training and capacity building available to our staff

Bullen provide training to all staff on all aspects of our code of conduct, values, circle of trust and compass point through our in-house Stoma & Urology Academy. More details can be seen at www.bullens.com

Updates to policies are communicated to all staff via the Workplace internal communications platform, and all staff have access to all policies and the employee handbook stored on the Bullen Intranet. Staff without PC access as part of their job can access these via PCs in the staff break-out area.

Training relating specifically to the Modern Slavery Act 2015 is made available to any staff who need it. This is most relevant to the Procurement Team and the HR Team.