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Anti-modern slavery & human trafficking statement

Introduction

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 2018.

The Statement was approved by the Board of Marie Stopes International ("MSI") on 12 July 2019.

Organisational Structure

MSI 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 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. We also distribute and market affordable and high-quality condoms, contraceptive pills and other contraceptive products to pharmacies, community based distributors and other private providers.

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 and maintenance
  • Research and evaluation
  • Finance and audit
  • Legal
  • Marketing and communications
  • Security
  • Information technology
  • Waste management

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 and Anti-Human Trafficking Policy ("Slavery Policy") and Implementation Procedures for the Modern Slavery Policy ("Slavery Procedures'). 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.

Additionally, all our employees are required to sign our Code of Conduct which includes a commitment to anti-modern slavery principles. 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.

Employment Practices

We commit to ethical principles in our employment practices. We do not use forced, bonded or child labour. Our employees are free to terminate their employment upon 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 following policies:

  • Global Equality and Diversity Policy
  • Global Dignity at Work Policy
  • Sexual Harassment Policy
  • Global Child Safeguarding Policy
  • MSI Adult Safeguarding Policy for International Operations
  • MSI Client Follow-up Guidance
  • Global Speaking Up Policy

Due Diligence on Business Partners

We require those who assist us to implement donor funded projects ("external partners"), and those from whom we procure ("suppliers"), to have the same approach to modern slavery and human trafficking that we have.

We also do the following when working with suppliers and partners:

  • Enforce our Global Due Diligence Policy which requires all suppliers to agree to our Business Partner Code of Conduct covering employment practices associated with "modern slavery," and undergo vetting against a global database of sanctions and other published lists of serious crime, misconduct and politically exposed persons.
  • Ensure that the approach taken by external partners who work with us in delivering aspects of our donor funded programmes, in relation to implementing anti-modern slavery processes, is considered when deciding whether to work with them.
  • 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 undertaking.

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 global intranet. Managers are also required to ensure that their team members adhere to the Code of Conduct and are aware of the principles of the Slavery Policy and Procedures, and uphold MSl's zero tolerance approach.

All head office staff working in the International division are required to complete e-module training on modern slavery. We have also delivered further training to MSI employees working in human resources and procurement, due to the higher risks of modern slavery in those areas.

All Marie Stopes UK staff (which is the entity operating MSI healthcare clinics in the UK) are required to complete e-module training on safeguarding, which incorporates modern slavery. Marie Stopes UK also requires certain staff to undertake advanced levels of safeguarding training incorporating modern slavery, delivered in e-modules and face to face.

Our trainings are designed to equip staff on how to recognise signs of modern slavery and how to report suspicions of modern slavery.

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 MSl's Speaking Up Policy set out a system for reporting concerns for employees, external partners and suppliers. We also have an external independent speaking up hotline through which any misconduct, including suspicions of any activity which could amount to modern slavery, may be reported.

Our Commitments

We are committed to continue taking actions which affirm our zero-tolerance approach to modern slavery. In March 2019 we became a participant to the United Nations Global Compact ("UNGC") in support of the UNGC's ten principles relating to Human Rights, including the principle of elimination of all forms of forced and compulsory labour.

In 2019 we are undertaking a further review of modern slavery risks in our supply chain and will assess any areas where our approach to modern slavery can be enhanced.

Review

This Statement is reviewed by the trustees annually and updated as appropriate.

Signed by:

Tim Rutter
Chair of the Trustees of Marie Stopes International
Date: 12 July 2019