Published: 8th August 2024 - All information correct at time of publication.
Introduction
This is SYNLAB UK & Ireland’s Modern Slavery and Human Trafficking Statement under Section 54 of the UK Modern Slavery Act 2015 for the financial year 2023.
Modern slavery is a broad term that encompasses slavery, servitude, forced and compulsory labour and human trafficking. SYNLAB UK and Ireland is part of SYNLAB Group which is committed to the UK Government’s objectives of eradicating modern slavery and human trafficking. SYNLAB UK & Ireland is committed to ensuring that the supply chains of its subsidiaries and their business activities trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and supply chain.
This statement summarises the measures that the SYNLAB UK & Ireland 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 Group offer services in more than 30 countries across four continents (Europe, Latin America, Africa and Middle East/Asia), having more than 27,000 employees including 3,000 employees across the UK & Ireland.
SYNLAB UK & Ireland’s operating business activities are carried out by Labco UK Group Limited and its subsidiaries. We provide analytical, diagnostic and pathological services in the fields of human medicine and toxicology.
In providing our services, we rely on the supply of technical equipment provided by suppliers of analytical machinery and technology for laboratory analyses/diagnostic testing, as well as reagents, chemicals and laboratory consumables utilised in such testing.
Goods and services are provided by professional services companies, 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 its corporate and financial housekeeping.
Our Policies
We have a Code of Conduct, issued to all new employees, setting out our commitment to act ethically and with integrity in all our business relationships. There is also a dedicated policy on anti-slavery and human trafficking. All our employees 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 of SYNLAB.
We utilise SYNLAB Group’s Supplier Code of Conduct, introduced as part of its plans for Responsible Supply Chain management. Key principles include advocacy for anti-slavery training and ensuring purchasing practices do not put undue pressure on suppliers.
In 2023 the Group also implemented an updated global ‘Speak Up’ reporting arrangements to encourage workers to “speak-up about their concerns knowing that there is protection from reprisals in place”. This was further supported in 2023 by the launch of SYNLAB Group’s Human Rights Strategy, policies and practices which flow down into SYNLAB UK & Ireland’s operations.
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 the inclusion of our relevant functional teams, such as legal, compliance, and procurement at the earliest stages of tendering and ensuring they have advanced levels of training in this and other ethical business areas. We are continuing to support efforts to tackle modern slavery by implementing various instruments, including the introduction of Modern Slavery Act (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 chain, risk assessments and due diligence will continue to focus on our first-tier supplier relationships. Our risk-based approach to supply chain management has identified that international suppliers of laboratory consumables are our priority. All parts of our business use this group of suppliers and therefore this is a priority area to audit against our code of conduct.
We are continuously taking steps to improve our systems and procedures to detect potential modern slavery and human trafficking risks arising around particular products and geographical areas.
Our efforts are overseen by SYNLAB Group, who has a dedicated Compliance Committee consisting of the Group Chief Executive Officer and Group Chief Financial Officer, chaired by the Group Chief Compliance Officer. The Compliance Committee is supported by Regional Compliance Officers, which includes the Head of Legal and Compliance for SYNLAB UK & Ireland.
Effective Actions Taken
We use the following key performance indicators (“KPIs”) 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:
Supplier engagement: All new supplier contracts include an anti-slavery and human trafficking clause in our supplier contracts; our KPI this area is to achieve 100% adherence. In addition, we have amended procurement contracts of our top global first tier supplier to confirm MSA compliance within our supply chain.
Training: To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, all current employees in the UK have to complete a training module annually on modern slavery and human trafficking. New employees must complete this training within the first two weeks of their employment with SYNLAB UK & Ireland. Our target is that 95% of employees, at any one time, will have completed this training module over the previous 12 months.
Complaints/Concerns: We will take any concerns raised about modern slavery either within our workplaces, our supply chain or the communities in which we operate seriously and provide access to a confidential, independent, free method of reporting these concerns. Our target is to have zero concerns.
Performance against these KPIs during 2023 was as follows:
| Area | Target | Achieved |
|---|---|---|
| Supplier engagement | 100% | Not assessed (new measure) |
| Training | 95% | 92.8% |
| Complaints raised | 0 | 0 |
Looking Ahead
We understand that combating modern slavery and human trafficking is an ongoing imperative. In 2024, we will continue to invest in doing so. Our actions will comprise of:
Communication: We will continue to raise awareness on modern slavery and human trafficking among our employees, ensuring they have access to an independent, confidential method of raising concerns.
Supplier Questionnaire: We will issue our supplier questionnaire to our suppliers as a mandatory feature of our onboarding process. This will form part of an updated supplier selection and on-boarding process that will be subject to audit from 2025 onwards to ensure this control is operating effectively.
Governance: Revised governance and business unit performance reporting will be implemented to support improved performance against our stated KPIs.
Thomas Evans
Director
Labco UK Group Limited
For our 2023 Modern Slavery and Human Trafficking Statement please click here
