LSAS Policy

It is the firm belief and policy of the Management Team of IMS Euro Group (which Comprises IMS Euro Group Ltd and its Subsidiaries) that throughout all its dealings, it will operate on an ethical basis towards its customers, suppliers and employees. To achieve this it will ensure that in its own direct operations, it complies with all national and international laws and conventions concerning labour standards. Additionally, it applies this principle to its supply chain.

Labour Standards Assurance System PM01

1. Labour Standards – Supply Chain Management

IMS Euro Group ensures that its first-tier suppliers and sub-suppliers within the supply chain operate safe and ethical manufacturing operations and abide by any national and/or international legislation relating to labour laws. To this end, IMS Euro Group has defined a set of minimum labour standards based upon the following sources;

· NHS Code of Practice

· NHS Labour Standards Assurance Scheme (LSAS)

· International Labour Organisation (ILO)

· United Nation’s Universal Declaration of Human Rights (UDHR)

IMS Euro Group has adopted a risk-based approach to labour standards issues within the supply chain. The activities that are risk-assessed and monitored are as follows;

2. Child Labour

IMS Euro Group does not engage in, or support the use of child labour, defined as labour that is mentally, physically, socially or morally dangerous and harmful to children and interferes with their schooling by;

• Depriving them of the opportunity to attend school

• Obliging them to leave school prematurely

• Requiring them to attempt to combine school attendance with excessively long, heavy and dangerous work.

IMS Euro Group will not contract with any organisation that employs children less than 15 years of age, under any circumstances.

3. Forced & Compulsory Labour

IMS Euro Group shall not engage in or support the use of forced or compulsory labour, bonded or involuntary prison labour within the organisation and within the supply chain. Workers are free to leave upon reasonable notice or when there is imminent danger.

4. Health & Safety

IMS Euro Group shall provide a safe and healthy workplace environment and shall take effective steps to prevent potential accidents and injury to employee health by minimising, so far as is reasonably practicable, and in co-operation with its workers, the causes of hazards inherent in the workplace. The same shall be expected of suppliers and sub-suppliers. All workers shall receive safety and job-specific instructions during the course of their employment with IMS Euro Group. Workers shall have access to clean, sanitary facilities and drinking water throughout the supply chain.

5. Freedom of Association

IMS Euro Group respects the rights of individuals with regards to freedom of association and shall comply with UK labour legislation and ensure that suppliers follow suit.

6. Discrimination

IMS Euro Group or any of its first-tier suppliers and sub-suppliers shall not engage in, or support any discriminatory practices / grievances in hiring, remuneration, access to training, promotion, termination or retirement based on race, national or social origin, caste, religion, gender, sexual orientation, political affiliations, age or other conditions that could give rise to discrimination. Refers to Human Rights Act (1998) & Equality Act (2010).

7. Disciplinary Practices

IMS Euro Group, its suppliers and sub-suppliers shall treat all workers with dignity and respect. The organisation, its first-tier suppliers or sub-suppliers shall not engage in, or tolerate the use of corporal punishment, mental or physical coercion or verbal abuse of personnel. No harsh or inhumane treatment is allowed.

8. Working Hours

IMS Euro Group shall comply with applicable national laws and industry standards on working hours and holiday entitlements. The same shall be required of all first-tier suppliers and sub-suppliers.

9. Remuneration

IMS Euro Group shall comply with national laws and regulations with regard to wages and benefits in accordance to the National Living Wage. All work-related activities are carried out on the basis of a recognised employment relationship established according to national law and practice.

IMS Euro Group also commits to;

Comply with relevant legal undertakings.
Ensure that all its key contractors and suppliers are aware of this policy and aspire to the same standards.
Make available sufficient resources for the implementation of this policy.
Carry out regular reviews of this policy to ensure that it remains fit for the purpose of which it is intended.

10. Roles & Responsibilities

All directors and employees have a responsibility to abide by the provisions of this policy.

The ultimate responsibility for the maintenance and adherence to this policy lies with the NHS Co-ordinator, who has also been appointed as the management representative for all labour standards issues within the IMS Group Ltd supply chain. This document is publicly available on the IMS Euro Group website.

Sam Collard
Chief Executive Officer
IMS Euro Group

Labour Standards Assurance System PM02

Overview

It is the clear policy of IMS Euro Ltd (IMS) to comply with all relevant legislation both in the United Kingdom, and any other country that the suppliers and sub-suppliers are within IMS’ chain of supply.

IMS will monitor and update a range of policies that are relevant to its own UK operation. It will also monitor its first tier suppliers and sub-suppliers’ policies to ensure that they are in place, reviewed and updated regularly. As far as possible, IMS will take steps to ensure that all suppliers adhere to the policies that they have in place.

The relevant policy documents will cover;

Health and Safety issues (including a Health and Safety training policy)
Human Resources
Labour Standards
Corporate Social Responsibility
Policies related to the selection of sub-contractors

IMS will require all sub-contractors to provide copies of their relevant policy documents, and to confirm that these comply with the appropriate legislation in their own country, and to formally confirm that they adhere to these policies.

It is a fundamental requirement within the IMS supply chain that all suppliers operate safe and ethical manufacturing operations and abide by any local legislation regarding the age of workers, their working condition and minimum wages.

IMS will not contract with any organisation that employs children less than 15 years of age, under any circumstances.

The senior managment of IMS are aware of current UK legislation relating to bribery and other inappropriate inducements and will not tolerate any breaches of this legislation either within its own team or amongst our suppliers.

Where the senior management of IMS do not possess the necessary skills or knowledge to fully implement this procedure, it will utilise the services of external consultants or others that have the necessary knowledge to assist.

1. SECTION 1 – Policy

The IMS senior management are aware of the NHS Suppliers Code of Conduct. They have a clear policy that complys with this Code of Conduct, which is also based on the Chartered Institute of Purchasing and Supply’s Professional Code of Ethics.

The key elements of this Code of Conduct cover;

Maintaining integrity in business relationships
Rejecting improper business practice
Declaring any potential personal or business conflicts of interest
Acquiring & maintaining latest standards of technical knowledge & ethical behavior
Optimizing the use of resources
Compliance with UK law, industry guidelines and contractual obligations
Fair, honest and respectable treatment of suppliers
Common courtesy at all times
Incorporating sustainable procurement aspects into the procurement processes, including human rights, employee rights and the protection of the environment.

IMS support the aims and principles of the United Nations Global Compact, The United Nations Universal Declaration of Human Rights and the 1998 International Labour Organisation Declaration of the Fundamental Principles and Rights at Work.

Under no circumstances will IMS contract with any organisation utilising forced labour or any organisation using any illegal or unethical practices in their recruitment. We will not contract with any organisation that discriminates on the grounds of race, religion, age, gender, disability or sexual orientation.

2. SECTION 2 – Management Representative

The senior management of IMS have nominated Mrs Julie Moores & Alan McCarthy (NHS Co-ordinator & Quality Assurance Mnager) as the Management Representatives for all LSAS activities and having overall responsibility for overseeing and reviewing labour standards both within the company and the suppliers and sub-suppliers. They will be supported in this task by Sue Henshaw-Welch, Operations Project Manager (UK).

The specific tasks to be undertaken by the Management Representative are;

To require all suppliers and sub-suppliers to provide information related to Labour Standards via the IMS Supplier Assesment Questionaire.
To provide awareness training on LSAS to all employees within IMS who come into contact with Labour Standards.
To ensure that the designated representatives from IMS’ suppliers and sub-suppliers, that have overall responsibility for LSAS compliance clearly understand their role, responsibilities and have documentary evidence to indicate that such roles and responsibilities have been unambiguously defined.
To undertake regular interviews at least annually, either face to face, by telephone or as a last resort by exchange of emails, to ensure that the designated representatives of the suppliers and sub-suppliers understand their role and that they can demonstrate that they are taking the appropriate steps to ensure LSAS Level 2 compliance.

3. SECTION 3 – Labour Standards Status Review

IMS acknowledges that there is the potential for abuse of workers in the countries where suppliers and sub-suppliers are based. It will not tolerate any such abuse and all suppliers and sub-suppliers will be required to provide evidence that they comply with all national and relevant international legislation.

As such, IMS will undertake a risk assessment at regular intervals of no more than twelve months to identify how such legislation can impact our its business and how breaches of compliance amongst its sub-contractors could lead to termination of supply contracts and therefore disrupt its own supplies.

In order to mitigate such risks, wherever possible, IMS will operate a policy of (at least) dual supply to ensure continuity until such time that breaches are rectified or alternative (fully compliant) suppliers are identified.

IMS’ risk assessment will include an evaluation of all suppliers and sub-contractors who are involved in the supply of medical products to NHS SC.

All key issues covered by the aims and principles of the United Nations Global Compact, The United Nations Universal Declaration of Human Rights and the 1998 International Labour Organisation Declaration of the Fundamental Principles and Rights at Work will be considered. It will also consider the effects, compliance and implications of our policies detailed in the overview to this document.

As part of the risk assessment IMS will identify how the International Labour Standards (detailed above) relate to IMS, both directly in the organisation as well as with the suppliers and sub-suppliers.

In addition to covering its own operations in this risk assessment, IMS will also asses the sub-contractors and suppliers of their own operation.

As appropriate, and as part of our own risk assessment and those of our sub-contractors we will invite and consider the views of other relevant stakeholders and interested parties.

Reference: OP01 Labour Standards Review Procedure

4. SECTION 4 – Legal & Other Requirements

In order to maintain up to date information regarding all aspects of Human Resource management, including legislation in both the United Kingdom and other countries where our suppliers and sub-suppliers are located, we will utilise the services of technical experts who specialise in those fields.

This external resource shall also provide updates, as appropriate, of any changes to Human Rights Legislation that is relevant to IMS, including any legislation that directly affects our existing and potential suppliers and sub-suppliers.

Within IMS, the Management Representatives have overall responsibility for assuring labour standards within our supply chain. The Management Representatives are responsible for ensuring that they are fully acquainted with all aspects of Human Rights and Human Resources legislation as it affects IMS.

Reference: OP02 Documentation & Records Control

5. SECTION 5 – Objectives, Targets & Progammes

IMS has established targets for labour standards assurance and these targets are covered in a separate document.

Objectives and targets shall be reviewed, and in necessary, updated at intervals of no longer than one year. The management review shall be the framework for the setting and monitoring of the objectives and targets.

All suppliers and sub-suppliers shall be required to meet applicable objectives and targets providing evidence of their compliance where appropriate.

6. SECTION 6 – Roles & Responsibilities

Roles and responsibilities related to Labour Standards have been defined within employees’ job descriptions and in terms of authority and reporting this is defined within the organisation chart, (See Appendix 2).

7. SECTION 7 – Competence, Training & Awareness

IMS shall ensure that the Management Representatives including all staff and employees are trained.

The minimum training shall be the on the documents that are linked to the LSAS audit report.

8. SECTION 8 – Communications

All supplier and sub-supplier reviews shall be fully documented by the Management Representatives. The Management Representatives will have personal responsibility for responding to any communications relating to LSAS compliance and reviews, whether such communications are with suppliers, sub-suppliers or stakeholders (including the NHS and other clients).

In the case of non-compliance being reported by IMS the individual concerned will be protected from any adverse action by the existing Whistle Blower policy contained in the Staff Handbook. Any information received from a whistle blower will be treated in the strictest confidence with the source of any non-compliance being treated in the strictest of confidence.

IMS shall detail its compliance with LSAS Level 2 (and in due course higher levels) on its website and in relevant sales related documentation.

The Management Representatives will provide a report at each board meeting in which they will provide an update on the progress made in monitoring the results of LSAS related investigations and general progress regarding Human Resources and Human Rights issues.

Outline information regarding suppliers and sub-suppliers progress relating to LSAS related performance and in particular the status (pass or fail) of all subcontractor reviews will be passed to all IMS staff as part of the existing management information process.

Reference: OP03 Communications Procedure

9. SECTION 9 – Documentation & Records

Documents required by the labour standards assurance system shall be controlled using this procedure. All documents shall be approved by the Management Representatives who are in regular contact with senior managers of IMS. Each document shall be controlled by an issue number and date last revised.

Reference: OP02 Documentation & Records Control Procedure

10. SECTION 10 – Operational Control

As part of its regular subcontractor review processes, IMS shall include questions to the subcontractors regarding compliance with Human Resources and Human Rights issues.

These questions which are in addition to the full LSAS compliance questionnaire and review process will include:

Any new supplier contracted to supply goods will sign the Policy Statement, committing to the obligations stated within this document. This will help enforce labour standards through the supply chain and reduce the risk of non-compliance from initial contact.
When IMS are placing orders with Suppliers, they will agree a suitable time scale that the quantity of goods can be produced without the need to increase: Levels of overtime or increasing staff levels (including tempory staff). This will help reduce the risk of forced labour, inhumane treatment, excessive overtime and the other possible breaches of labour standards.
Evidence may be collected as well as on site audits may need to be conducted to clarify any evidence given via the supplier assessment questionnaire – for example the age of the youngest employee via a proof of age document, time sheets for hours worked, payslips to clarify wage given and health and safety records.

If any of these control point highlight any potential issues, an agreed corrective action plan may be issued to help improve the labour standards of the manufacturer and help reduce the risk of any misconduct.

The questions addressed are considered to be the most critical areas of potential weaknesses or even non-compliance with current legislation, and will be raised immediately if issues arise.

11. SECTION 11 – Supply Chain Management

IMS shall maintain a list of all suppliers and sub-suppliers. All tier one suppliers shall be required to inform IMS if they, in turn, subcontract any work or purchase raw materials that are within the scope of supply.

All existing and potential suppliers/subcontractors will be informed of the IMS’ LSAS level 2 credentials and will be made aware that following the aims and principles of the United Nations Global Compact, The United Nations Universal Declaration of Human Rights and the 1998 International Labour Organisation Declaration of the Fundamental Principles and Rights at Work are mandatory if they are to become or remain IMS’ suppliers.

If information that any suppliers or sub-suppliers are breaching these aims, the Management Representative will immediately undertake an investigation to confirm, or eliminate, any such claims. If the claims are upheld, or if in the process of routine monitoring, any supplier or sub-suppliers are found to breaching these aims then no further orders will be placed with them until remedial action has been undertaken and verified.

Its risk assessment will include an evaluation of all suppliers and sub-contractors who may not necessarily be involved in the supply of medical products to NHS SC.

All written orders placed with the subcontractors will contain reference to the need to comply with Labour Standards requirements.

Reference: OP04 Supply Chain Management Procedure

12. SECTION 12 – EMERGENCY RESPONSE

If the aims regarding labour relations and human rights are found to have been breached by any supplier or sub-supplier, IMS shall not place any further orders with this supplier until remedial action has been taken and evidence has been presented to prove that the remedy has been fully implemented.

Reference: OP04 Labour Standards Review Procedure

13. SECTION 13 – Performance Monitoring & Measurement

The performance of all suppliers shall be monitored taking a risk based approach based upon the information that is supplied back to IMS. The risk based system defines the actions to be taken, in some cases third party audit reports shall be requested, in other cases an audit by IMS Euro will be done.

14. SECTION 14 – Corrective Action

All instances of non-conformity against labour standards and against these policies and procedures shall be recorded and an investigation shall take place. Some of these non-conformities may be highlighted through the Supplier assessment questionnaire, whistle blowers, news stories, as well as suspicion from staff internally and externally. The results of the investigation into the root cause being established and documented. All corrective actions shall be reviewed as part of the management review and minutes and actions documented.

Reference: OP05 Corrective Action Procedure

15. SECTION 15 – Management Review

The Director and senior managers of IMS, led by the Management Representative who is in contact with senior management shall provide an update on LSAS related issues at each board meeting and will arrange for a complete review of this document at regular intervals of no more than one year.

Any significant or serious lapses or deficiencies in adherence to LSAS related processes will be reported to all members of the Board of Directors.

APPENDIX 1: LIST OF PROCEDURES

OP01	Labour Standards Procedure
OP02	Documentation & Records Control Procedure
OP03	Communications Procedure
OP04	Supply Chain Management Procedure
OP05	Corrective Action Procedure

Updated & Reviewed February 2024