This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Anti-Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2017. The Statement was approved by the Board of MSI Reproductive Choices ("MSI") on 28 November 2018.
MSI Reproductive Choices is an international non-governmental organisation that provides sexual and reproductive healthcare, mostly to girls and women. We operate through branch offices and affiliates in 37 jurisdictions, many of them in the developing world. Our head office is in London.
Business and Supply Chain
We have a network of more than 600 healthcare clinics worldwide, we conduct outreach operations where we provide access to sexual and reproductive healthcare to remote communities, we partner with existing private health providers who deliver services on our behalf, we distribute and market affordable, high quality condoms, contraceptive pills and other contraceptive products to pharmacies, community based distributors and other private providers, and we engage mobile midwives - MS Ladies - to provide access to sexual and reproductive healthcare to girls and women in specific communities where there is unmet need.
The key areas in which we engage suppliers are:
- Staff recruitment
- Supply of medicinal products and medical devices
- Supply of non-medical equipment and consumables
- Facilities management
- Finance and Legal
- Marketing and communications
- Information technology
Our Policy on Slavery and Human Trafficking
As an organisation that promotes the rights of women and girls, we are absolutely opposed to modern slavery and human trafficking in all its forms. We are committed to enhancing and enforcing our systems and controls to ensure that modern slavery and human trafficking are not taking place in our supply chains or anywhere else in our business.
We have a Modern Slavery Policy ("Slavery Policy") and Implementation Procedures for the Modern Slavery Policy ("Slavery Procedures'), in addition to comprehensive procedures for conducting due diligence on business partners. The Slavery Policy and Slavery Procedures are disseminated to all staff, and we expect all staff to be aware of, and to discharge, their obligations under them. We will take any breach of the Slavery Policy and Slavery Procedures very seriously: any employee who commits a breach will be disciplined and may be dismissed.
We commit to ethical principles in our employment practices. In particular, we do not use forced, bonded or involuntary prison labour or child labour. Our employees are free to terminate their employment on reasonable notice. We do not demand fees from anybody who wishes to be employed by us, or retain any actual or potential employees' identity or travel documents. When we recruit, we only use reputable recruitment consultants, and we expect them to respect the human rights of all candidates. Our ethical principles extend to the terms and conditions of employment that we offer. As a minimum, we ensure that our employees' salaries and working hours comply with national law, and that our employees have a safe and hygienic working environment, and full access to grievance procedures. Further information on our employment practices may be found in the Slavery Procedures and in the follow policies:
- The Global Equality and Diversity Policy;
- Global Dignity at Work Policy/ Sexual harassment policy;
- Global Child Safeguarding Policy;
- the Global Speaking up Policy.
In addition we have a Code of Conduct signed by all staff which sets out the requirement for high standards of conduct to all and requires adherence to the principles underlying the Modern Slavery policy both within the organization and in our supply chain.
Due Diligence on Business Partners
We expect that those who assist us to implement donor funded projects ("external partners"), and those from whom we procure ("suppliers"), have the same approach to modern slavery and human trafficking that we have.
- Are implementing a new due diligence process which requires all suppliers to confirm their agreement to our code of conduct covering employment practices associated with “modern slavery”.
- Ensure that the approach taken by external partners to practices amounting to modern slavery is taken into account when deciding whether to work with them.
- Have amended our standard terms and conditions for the supply of goods and services, to ensure that suppliers undertake to comply with the underlying provisions of the Modern Slavery Act
- Ensure that, when we enter into a new contract with an external partner or supplier, we have the right to terminate that contract if the external partner or supplier breaches its anti modern slavery or human trafficking
- Have a Speaking-Up policy and external independent speaking up hotline (Safecall) through which any misconduct including suspicions of any activity which could amount to “modern slavery” may be reported
Where we believe that an external partner or supplier is involved in modern slavery or human trafficking, we will take steps to terminate our relationship with that partner or supplier as quickly as possible.
Training and Awareness
The Slavery Policy and the Slavery Procedures have been disseminated and are posted on the intranet. UK-based staff are required to complete e-module training covering modern slavery. Global teams working in high risk areas, such as human resources and procurement, are being given training tailored to their particular needs.
Reporting of Concerns
We recognise the importance of remaining vigilant to identify and address issues associated with slavery and human trafficking in the organisation and throughout our supply chains. The Slavery Policy and the Speaking-Up Policy set out a system for reporting concerns for employees, external partners and suppliers, including a speaking-up hotline that is confidential and independent of MSI.
This Statement will be reviewed by the trustees annually and updated as appropriate.
Chair of the Trustees of MSI Reproductive Choices
Date: 4 June 2020