This is the SYNLAB Group’s Modern Slavery and Human Trafficking Statement under Section 54 of the UK Modern Slavery Act 2015 (MSA) for the financial year 2019. It applies to all Group companies which are regulated under the MSA. Modern slavery is a broad term that encompasses slavery, servitude, forced and compulsory labour and human trafficking. Subsequently, the SYNLAB Group is committed to ensuring that the supply chains of its subsidiaries and their business activities are free from ethical and labour standards abuse. This statement summarises the measures that the SYNLAB Group has taken to assess and address the risk of modern slavery in its business and supply chains.
Our Organisational Structure, Business Model & Supply Chain
SYNLAB Limited is the ultimate parent company of all the subsidiaries that belong to the SYNLAB Group of companies (SYNLAB). SYNLAB Limited provides head office support activities to its subsidiaries by way of proving guidelines, advice and assistance. Trading within the UK, SYNLAB has two subsidiaries which meet the reporting requirements of the UK Modern Slavery Act: SYNLAB Bondco PLC is a non-operational debt issuing vehicle, proving financing to the SYNLAB Group; and Labco UK Group Limited carries out the majority of our operating business activities within the UK.
We are an international diagnostic service provider. We provide analytical, diagnostical and pathological services in the field of human and veterinary medicine diagnostic, hygiene analyses, environmental analysis, as well as laboratory services to the pharma and food sector, and related products. We offer our services in more than 40 countries in four continents (Europe, Latin America, Africa and Middle East/Asia), having more than 20,000 employees (Members).
In providing our services, we rely on the supply of technical equipment provided by suppliers of analytical machinery and technology for laboratory analysis/diagnostic testing, as well as regents and chemicals utilized in such testing. Goods and services are provided by professional services companies as well as subcontractors including couriers and sub-processors of test samples. In addition, we rely on external professional services providers in relation to our head office support, including financing related activities as well as corporate and financial housekeeping.
We have adopted a Code of Conduct, setting out our commitment to act ethically and with integrity in all our business relationships. The Code of Conduct is currently being implemented within our Group and our Members receive training on it alongside the rollout. In addition, our UK entities have adopted a dedicated policy on anti-slavery and human trafficking. All our members must comply with all relevant laws and regulations (Including those on modern slavery and human trafficking) and they must respect the personal dignity, rights and diversity of everyone within and outside SYNLAB. We support all our Group companies with a view to ensure compliance with our Code of Conduct.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our Members.
Due Diligence & Risk Assessment
We acknowledge that slavery and human trafficking exist in many jurisdictions in which we operate, and/or from which we procure goods or services. Our overall objective is to establish and maintain relationships with our suppliers that will minimise the risk that slavery or human trafficking could occur within our supply chains.
Our due diligence approach is based on inclusion of our relevant functional teams, such as legal, compliance, M&A, human resources and procurement. We continuing to invest in tackling modern slavery by implementing various instruments, including the introduction of MSA provisions in our supplier contracts and the circulation of supplier assessment questionnaires.
To mitigate against the risk of modern slavery and human trafficking in our supply chains, risk assessment and due diligence will continue to focus on our first-tier supplier relationships. It is understood that we need to refine our risk assessments in accordance of our findings. We are taking steps to establish frameworks in which all elements of our supply chain are expected to observe applicable laws and operate in accordance with our Code of Conduct.
We have a dedicated Compliance Committee, which consists of the Group Chief Executive Officer and Chief Financial Officer, chaired by the Group Chief Compliance Officer. The Compliance Committee is supported by Regional Compliance Officers, submitting regular reports to the Office of the Group Chief Compliance Officer on compliance findings.
Effective Actions Taken
We use the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chain:
- Anti-slavery and human trafficking clauses: We included an anti-slavery and human trafficking clause in our procurement templates. In addition, we are amending existing procurement contracts of our top global first tier supplier to confirm MSA compliance within our supply chain.
- Training our Members: We carried out modern slavery and human trafficking training and workshops for the all vast majority of our Members in the UK and the most relevant Members of Group HR and Group Legal.
- Compliance reporting: In 2019, no compliance findings on modern slavery and human trafficking were reported by the Regional Compliance Officers.
We understand that combating modern slavery and human trafficking is an ongoing imperative. In 2020, we will continue to invest in doing so. Our actions will comprise:
- CEO Message: Our regular CEO message to our Members will emphasise on our social responsibly and ethical principles, including our rigorous standing against modern slavery and human trafficking.
- Policies: We plan to implement a dedicated policy on anti-slavery and human trafficking / human rights.
- Human Resources: We will improve transparency in our recruitment processes, and compliance with vetting standards for our Members and contingent labour.
- Training for our Members: We will continue to raise awareness on modern slavery and human trafficking among our Members. We will continue to train our Members in 2020, focusing on Procurement, Operations, Facility Management and Finance.
- Supplier Questionnaire: We will continue to issue our supplier questionnaire to our suppliers, continuing to ensure that our supply chain complies with our ethical standards set out in our Code of Conduct.
CEO & member of the Board of Directors for SYNLAB Ltd.
For our 2019 Modern Slavery and Human Trafficking Statement please click here.