Modern Slavery Act 2015
Slavery and Human Trafficking Statement for Year Ended 31 March 2024
1. Our Policy
DCC Vital is opposed to slavery and human trafficking in any part of our activities or our supply chains. We are therefore committed to ensuring that we have adequate policies and procedures in place to identify and prevent these practices.
We met the turnover threshold applicable under section 54 of the Modern Slavery Act 2015 in the period covered by this statement..
2. Our Business
We distribute a broad range of own- and third party-branded medical devices, pharmaceuticals and medical supplies to hospitals, pharmacies, GPs, laboratories, other healthcare providers and related industries in the UK, Ireland, Continental Europe and internationally. Seasonal work is not a feature of the industry in which we operate. More information on our business is available at https://www.dcc.ie/healthcare/dcc-vital.
We are the Patient Health business of DCC Healthcare; part of DCC Group. DCC is a leading international sales, marketing, and support services group with a clear focus on performance and growth. Its headquarters are in Dublin, Ireland. It is listed on the London Stock Exchange and is a constituent of the FTSE 100 Index.
DCC currently has operations in 22 countries and employs over 16,000 people.
Additional information on the Group is available at http://www.dcc.ie/.
3. Organisational Structure & Supply Chains
In the period, our business was organised into the following Divisions:
- Medical Devices
- Primary Care
- Ireland
- Logistics
See appendix for details on the companies within each Division
Our primary supply chain partners are authorised medical device and pharmaceutical manufacturers and distributors. The large majority of these are reputable suppliers who are based in the UK, US, and European Union. Where we deal with suppliers in countries where this risk is higher, we have put more robust controls and due diligence in place.
The following table contains a summary of the activities that we consider present the highest risk of slavery and human rights violations in the industries in which we operate, with, in each case, a summary of the steps we have in place to avoid these affecting our activities or our supply chains.
4. Our Policies on Slavery and Human Rights Violations
The DCC Code of Conduct sets out our Group’s commitment to acting ethically and with integrity towards our employees and in all our business relationships. Specifically, Section 2 of the Code sets out our commitment to fair employment practices and Section 14 of the Code sets out our commitment to preventing, as far as practicable, slavery and human rights violations in our supply chains.
The DCC Group Supply Chain Integrity Policy sets out the approach taken by every business in the DCC Group to ensuring that all the products we sell meet applicable legal and ethical standards, including human rights and minimum labour standards.
In addition, the DCC Human Rights Policy sets out DCC’s specific commitment to operate to internationally recognised standards of human rights, including in relation to forced labour, child labour and unsafe working conditions.
These documents are available at https://www.dcc.ie/sustainability/governance-and-compliance.
Our policy on slavery and human rights violations is set out in Section 1 of this statement.
At DCC Vital, we have established our Supply Chain Integrity and Anti-Bribery and Corruption Risk Assessment Procedure and Supply Chain Integrity Code of Practice to reflect the requirements of these Group policies. These documents outline the detailed requirements we follow at DCC Vital and which have been integrated into local company procedures. A number of DCC Vital companies participate in third-party assessment and audit programmes such as the NHS Labour Standards Assurance System and ECOVADIS. Our companies also participate in customer evaluations of our compliance to labour standards and modern slavery requirements.
5. Due Diligence and Assessing and Managing Risk
As part of our compliance with the policies and procedures referred to above, we take the following steps:
- Assess potential risk areas in our supply chains, including where partners or potential partners are located in countries where slavery or human rights violations are a particular risk. The risk assessment considers the industry or geographies in which they operate. Geographic risk, for this purpose, is informed by relevant independent indices such as the Corruption Perceptions Index or Global Slavery Index;
- Carry out enhanced due diligence on certain partners following this risk assessment. As a DCC Group business, we work mainly with Kroll, a leading supplier of integrity due diligence services, in this area. Where red flags are identified in this due diligence, senior management are involved;
- Mitigate the risk of slavery and human rights violations occurring in our supply chains, including by reviewing, where necessary, the controls that our partners have in place, asking partners to confirm that they meet certain standards and carrying out other suitable checks including audits;
- Monitor potential risk areas in our supply chains on a periodic basis and repeat due diligence where appropriate.
Steps we have taken in the period to enhance our process for identification of slavery and human rights violations risks in our supply chain are set out below: - DCC Vital have completed timely and comprehensive risk assessments and due diligence of third parties associated with our acquisitions in line with our Supply Chain Integrity and Anti-Bribery and Corruption Risk Assessment Procedure.
- We have continued to develop our online due diligence portal to monitor, track and record our risk assessment and due diligence activities. This data is reported quarterly as part of the DCC Vital Compliance dashboard.
- We have conducted a review of our processes including engaging third-party support. Relevant procedures and documentation have been updated and rolled out to all businesses.
As part of our compliance with the policies and procedures referred to above, we take the following steps:
• Assess potential risk areas in our supply chains, including where partners or potential partners are located in countries where slavery or human trafficking are a particular risk. The risk assessment considers the industry or geographies in which they operate. Geographic risk, for this purpose, is informed by relevant independent indices such as the Corruption Perceptions Index or Global Slavery Index;
• Carry out enhanced due diligence on certain partners following this risk assessment. As a DCC Group business, we work mainly with Kroll, a leading supplier of integrity due diligence services, in this area. Where red flags are identified in this due diligence, senior management are involved;
• Mitigate the risk of slavery and human trafficking occurring in our supply chains, including by reviewing, where necessary, the controls that our partners have in place, asking partners to confirm that they meet certain standards and carrying out other suitable checks including audits;
• Monitor potential risk areas in our supply chains on a periodic basis and repeat due diligence where appropriate.
Steps we have taken in the period to enhance our process for identification of slavery and human trafficking risks in our supply chain are set out below:
• DCC Vital have completed timely and comprehensive risk assessment and due diligence of third parties associated with our acquisitions in line with our Supply Chain Integrity and Anti-Bribery and Corruption Risk Assessment Procedure.
• We have continued to develop our online due diligence portal to monitor, track and record our risk assessment and due diligence activities.
• We have conducted a review of our processes including engaging third-party support. Relevant procedures and documentation will be updated and rolled out to all businesses
6. Assurance and Key Performance Indicators
Responsibility for ensuring that our policies and procedures are adequate and are adhered to in all areas of our activities rests with the senior management team of DCC Vital. Regular updates are provided to the DCC Vital Compliance Committee and DCC Vital Leadership Team for review and feedback. Our policies and procedures are audited periodically by internal auditors and by third parties to assure compliance and to identify areas for improvement. These audits address supply chain integrity risks including the abuse of human rights and employment rights. We utilise our online due diligence portal to enable metrics and monitoring of our activity and performance.
We report on compliance with the DCC Group Code of Conduct and Supply Chain Integrity Policy every six months.
7. Training & Awareness
In the period covered by this statement our business completed almost 700 employee compliance training modules across our Code of Conduct, Doing Business in High Risk Countries, Competition Law and Preventing Bribery & Corruption which covered the protection of human rights, including the prevention of slavery. This training is rolled out regularly to all employees.
We also provide training to relevant employees on supply chain risks, including the risk of slavery and human trafficking in accordance with our procedure requirements. A comprehensive bespoke training programme is in place and is carried out periodically across the business including employees from Commercial. Finance, Procurement, Quality Departments plus Senior Management and Compliance Committee members. Training in our updated procedure will be rolled out in the coming year.
Our participation in industry associations and our dealings with third party partners also provides DCC Vital with information regarding slavery and human trafficking risks in the industries where DCC Vital is active, and best practice in avoiding them.
In the period covered by this statement, we completed over 1800 compliance training sessions across our employee population, in particular for our newly acquired businesses covering our Code of Conduct, Data Privacy and Protection, Competition Law, Preventing Bribery & Corruption and Doing Business In High-Risk Countries, which covered the protection of human rights, including the prevention of slavery. This training is rolled out regularly to all employees.
We also provide training to relevant employees on supply chain risks, including the risk of slavery and human rights violations in accordance with our procedure requirements. Training in our updated procedure has been rolled out in the period.
Our participation in industry associations and our dealings with third party partners also provides DCC Vital with information regarding slavery and human rights violations risks in the industries where DCC Vital is active, and best practice in avoiding them.
8. Nature of this Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human rights violations statement for the financial year ending 31 March 2024.
This statement has been approved by the DCC Vital Leadership Team.
Conor Costigan
CEO DCC Healthcare
June 2024
