Anti-Slavery Policy

Last updated: 30 October 2026 (Version 1.0). Next review: October 2027.

Purpose/Aim/Scope

Best Ever Medical Devices (BEMD) has a zero-tolerance approach to modern slavery and human trafficking in any form. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to putting in place effective systems and controls to make sure modern slavery is not taking place anywhere in our own business or in our supply chains.

This policy sets out how BEMD meets that commitment. It is based upon:

The Human Rights (Bailiwick of Guernsey) Law, 2000, which gives effect to Article 4 of the European Convention on Human Rights (prohibition of slavery and forced labour)
The UK Modern Slavery Act 2015, as BEMD sells products to customers in the United Kingdom
The International Labour Organization (ILO) Forced Labour Convention, 1930 and its 2014 Protocol

This policy applies to all employees (permanent, contractors, management, temporary staff and volunteers) of BEMD, and to anyone acting on our behalf. We also expect our suppliers, manufacturers, distributors, carriers and other business partners to meet the standards set out in this policy.

BEMD is not currently required to publish an annual slavery and human trafficking statement under section 54 of the UK Modern Slavery Act 2015, as its turnover is below the £36 million threshold. We publish this policy voluntarily as a statement of our values and our approach.

Definitions

Modern Slavery: An umbrella term covering slavery, servitude, forced or compulsory labour and human trafficking.

Slavery and Servitude: Where a person is treated as if they were owned by another, or is obliged to provide services and is unable to change their circumstances.

Forced or Compulsory Labour: Work or services taken from a person under the threat of a penalty, which they have not offered voluntarily. This includes debt bondage and the withholding of identity documents or wages.

Human Trafficking: Arranging or helping the travel of another person with a view to them being exploited.

Child Labour: Work that deprives children of their childhood, their potential and their dignity, or that is harmful to their physical or mental development.

Supply Chain: All the businesses and individuals involved in providing BEMD with goods and services, including the manufacture of our products, packaging, warehousing, distribution and delivery.

Policy Statement

BEMD will:

Never use, or knowingly benefit from, slavery, servitude, forced or compulsory labour, human trafficking or child labour
Treat everyone who works for us fairly, pay at least the applicable minimum wage and provide written terms of employment
Never ask workers to pay recruitment fees, and never hold their identity documents, passports or wages
Choose suppliers carefully and expect them to apply the same standards in their own businesses and supply chains
Act promptly on any concern that modern slavery may be taking place, and co-operate fully with the authorities

Roles and Responsibilities

Director

The Director, Jim Marshall, has overall responsibility for this policy and for making sure BEMD meets its legal and ethical obligations. The Director will:

Make sure this policy is understood, applied and resourced within the organisation
Carry out supplier due diligence and keep records of it
Act as the first point of contact for any concern raised under this policy
Review this policy annually, or sooner if the business or the law changes

All Staff

All staff must read, understand and comply with this policy. Everyone must avoid any activity that might lead to, or suggest, a breach of this policy, and must report any concern as soon as possible.

Our Business and Supply Chains

BEMD is a small company registered in Guernsey that designs and sells medical devices, including the Horse Tendon Pad. We sell directly to customers through our websites and through authorised distributors, and we send orders by tracked postal and courier services.

Our main supply chain risks lie in the manufacture of our products and their components, and in the packaging, storage and delivery of those products, some of which may take place outside the Bailiwick of Guernsey. We consider these areas when choosing and reviewing suppliers.

Due Diligence and Risk Assessment

To identify and reduce the risk of modern slavery in our supply chains, BEMD will:

Assess the risk of each new supplier before working with them, taking account of the country, the industry and the type of work involved
Ask key suppliers, particularly manufacturers, to confirm in writing that they comply with this policy and with all relevant laws on employment, wages, working hours and health and safety
Include anti-slavery requirements in new or renewed supplier agreements where possible, including our right to ask for information and to end the relationship if the requirements are not met
Keep records of the checks we carry out
Review suppliers regularly, and immediately if a concern is raised

Warning Signs

Staff should be alert to signs that may indicate modern slavery, including:

Workers who appear frightened, controlled by someone else, or unable to speak for themselves
Workers who do not have their own identity documents
Very low prices, unexplained subcontracting or a reluctance to share information about where or how goods are made
Workers living on site, or in poor or overcrowded accommodation provided by their employer

Recruitment and Employment

BEMD will check that every employee has the legal right to work in the Bailiwick of Guernsey, pay wages directly into a bank account in the employee’s own name, and never charge fees for recruitment. Where an employment agency is used, BEMD will only use reputable agencies and will check their practices.

Reporting a Concern

Anyone who suspects that modern slavery is taking place in BEMD’s business or supply chains should report it straight away. Concerns can be raised:

With the Director, by email to info@bestevermedical.com
With Guernsey Police on 01481 222222
With the UK Modern Slavery and Exploitation Helpline on 08000 121 700 (free, confidential and open 24 hours a day)

If someone is in immediate danger, call 999.

BEMD will treat all reports confidentially and will investigate them promptly. Nobody will suffer any detriment for raising a genuine concern in good faith, even if it turns out to be mistaken.

Training and Awareness

All staff will be made aware of this policy when they join BEMD and whenever it is updated. Staff who deal with suppliers will be given guidance on recognising and reporting the signs of modern slavery.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which may lead to dismissal. BEMD may end its relationship with any supplier, distributor or other business partner who breaches this policy.

Monitoring and Review

The Director will review this policy and the effectiveness of our due diligence at least once a year. This policy is published on our website and is available to anyone on request.