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Modern Slavery Policy



This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 January 2024.

Sterling Medical Supplies Ltd. (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational Structure

Sterling Medical Supplies Ltd. and has business operations in the United Kingdom.

We operate in the medical sector. The nature of our supply chains is as follows: We work with several key direct suppliers, who provide us with medical supplies and equipment for our business operations and customer fulfillment.

For more information about the Company, please visit our website: http://www.sterlingmed.co.uk


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

These include the following:

Recruitment and selection policy – Implementing a robust recruitment and selection policy is crucial to preventing modern slavery in the UK. By conducting thorough background checks, verifying the credentials of potential hires, and promoting transparency in the hiring process, your company can ensure that it does not inadvertently engage with individuals or entities involved in exploitative practices, contributing to the broader effort to eradicate modern slavery from the workforce.

Supplier code of conduct – To prevent modern slavery, our company supplier code of conduct emphasizes rigorous due diligence in the sourcing of materials and labor. It mandates suppliers to uphold fair labor practices, ensuring workers are treated ethically, paid fair wages, and operate in safe conditions. Additionally, the code promotes transparency, requiring suppliers to disclose their supply chain information and demonstrate a commitment to eradicating any form of forced labor within their operations.

Whistleblowing policy – Our company’s whistleblowing policy serves as a vital tool in preventing modern slavery by providing a secure and confidential platform for employees to report any suspicious activities or ethical concerns related to potential exploitation. This proactive approach not only encourages transparency but also empowers our workforce to contribute actively to the eradication of modern slavery within our organizational boundaries.

Staff code of conduct – Our company staff code of conduct is designed to combat modern slavery by promoting ethical sourcing and supply chain practices. We strictly prohibit any form of forced labor, human trafficking, or exploitation within our operations. Through stringent vetting of suppliers and fostering a culture of transparency, we aim to ensure that our business activities align with the highest standards of human rights and social responsibility, actively contributing to the global fight against modern slavery.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

– Internal supplier audits.
– External supplier audits.

Our due diligence procedures aim to:

– Identify and action potential risks in our business and supply chains.
– Monitor potential risks in our business and supply chains
– Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
– Provide protection for whistleblowers.

Risk and Compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

– Evaluating the slavery and human trafficking risks of each new supplier.
– Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We do not consider that we operate in a high-risk environment because Our company prioritizes low-risk operations to ensure sustained stability and financial resilience. By implementing rigorous risk management strategies, we safeguard our investments, maintain customer trust, and foster a consistent and reliable business environment. This commitment to prudent risk management enables us to navigate uncertainties while positioning ourselves for long-term success.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.


The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

– We will contact suppliers to enquire about their modern slavery practices every 12 months.
– We will carry out a regular audit of suppliers – 80% of suppliers each year.

The statement was approved by the board of directors. Click here to view signed statement

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