This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Wright Health Group Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Wright Health Group Ltd is committed to the manufacture and supply of safe, legal products that meet or exceed statutory and customer requirements and that it conducts its business according to the standards of good ethical, employment and environmental practice contained in this policy. Modern slavery encompasses slavery, servitude, human trafficking and forced labour.

Wrights is working towards establishing a zero-tolerance position on violations of anti-human trafficking and anti-modern slavery laws. If we find breaches of these laws within our supply chain, we will look to support companies in their efforts to comply with the legislation. We will also actively consider how we support or conduct business with organisations involved in slavery, human trafficking, forced or child labour.

We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Wright Health Group Ltd expects its suppliers and partners to operate on the same principles.

Our business

Wright Health Group Ltd operates in the UK, Hungary, South Africa and USA and it’s principal activity continues to be the manufacture, import and purchase of dental equipment and material of all kinds and the distribution of these products both wholesale and retail in the UK, South Africa, USA and other overseas markets.


Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1.Ethical Employment Standards Policy. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
In applying this code Wright Health Group Ltd requires adherence to the specific requirements for social accountability as laid out in the International Standard – Social Accountability 8000 (SA8000) and the International Instruments (Conventions and Recommendations) are to be followed by the Company and the Supply Chain.

2. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

3. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.


Our suppliers

We recognise our Company is exposed to greater risk when dealing with its suppliers, particularly those who have operations/suppliers in other territories. We are working toward full implementation of the following measures by 2018 to review and manage this risk:
1. Examination of our supply chains. We have begun to map our supply chains for the year 2014/2015 and we will identify those suppliers to whom we pay £100,000 or more on an annual basis.

2. For those which we pay £100,000 and above (72% of spend) we will map these according to location, size and industry, to identify potential indicators of slavery, as follows:

a. Identify % of suppliers located within the UK or other low risk countries.
b. Identify those companies with an annual turnover of >£36m, who are therefore covered by the Modern Slavery Act requirements.
c. Identify % of suppliers in high risk countries – see figures 1
d. Identify % of suppliers in high risk sectors

In addition to the above, as part of our contract with suppliers, we are working towards a requirement that they confirm to us that:

1. They have taken steps to eradicate modern slavery within their business
2. They hold their own suppliers to account over modern slavery
3. (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
4. (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
5. We may terminate the contract at any time should any instances of modern slavery come to light

Training
We are currently training our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.


Our performance indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Going forward, we aim to work towards:
· Training – developing an employee training module that will be undertaken by all employees.
This training will outline what modern slavery is, how to identify it and what individuals should do if they suspect there are any cases of slavery occurring.
Completion of this training will form a compulsory part of our employees new start induction processes.
· Procedures – Developing a procedure to monitor how our suppliers comply with our supplier Code of Conduct.


Approval for this statement
This statement was approved on 04 September 2017 by:
Name: Mrs K A Souter – Finance & Operations Director
Signature: Date: 01 January 2017