MDDUSMDDUS is a mutual defence organisation working to protect and support healthcare professionals and organisations through its advisory, legal, financial, practice management and risk education services.
A private company limited by guarantee, MDDUS is the operating name of the holding company of the Group. There are four wholly owned subsidiaries: MDDUS Insurance Limited, an insurance company; MDDUS Solutions (the operating name of MDDUS Services Limited), an FCA authorised insurance intermediary; MDDUS Education Limited, a risk and training company; and MDDUS Property Limited (MPL), which oversees the management and performance of an investment property portfolio.
The Board is committed to a high standard of corporate governance. As a member of the Association of Financial Mutuals (AFM), MDDUS applies, and reports against, the principles of the AFM Corporate Governance Code (January 2019). The MDDUS operates only within the UK, the Channel Islands and the Isle of Man and complies with all relevant company law.
Zero-tolerance approach towards modern slavery
The MDDUS Board has a zero-tolerance approach towards slavery, servitude, forced or compulsory labour, human trafficking and exploitation, including as defined and prohibited by the Act. For the purposes of this Statement, these offences are collectively referred to as ‘modern slavery’.
Identifying potential risks
We believe that the professional-service nature of our business exposes us to a lower risk of the occurrence of modern slavery. Internal controls help to ensure that we comply with the Act, in particular our human resource procedures and pre-employment checks. We are committed to fair pay and no one working within MDDUS earns less than the living wage. We have introduced a range of health and wellbeing options, including mental health awareness sessions and first aiders, to support colleagues.
We believe, therefore, that our supply chain, particularly in relation to MPL, is the area of highest risk to our compliance with the letter and spirit of the Act. Our reputation is built on trust and integrity and, as such, we have particular expectations from our colleagues, sector partners and other organisations with whom we conduct business. We aim to form relationships only with those who demonstrate that people involved at any level in their business processes are treated with dignity and respect.
MPL is identified as a higher risk due to the nature of some property management work and because our relationship with these services is one-step removed. We work closely with our property manager in London, Daniel Watney, which is committed to ensuring there is transparency in its business and approach to tackling modern slavery in its supply chain. Daniel Watney’s modern slavery policy advises: ‘We include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards’.
We continue to develop our relationship with Knight Frank, the management agent for our new office in Glasgow.
We will be taking steps in 2022 to formalise our investment policy as it relates to environmental, social and governance (ESG) matters.
Our own standard contracts for the supply of goods and services include terms and conditions relating to modern slavery and the Act.
Assessing potential risks
We have a varied supply chain that extends to a range of products and services – for example, office equipment and supplies, promotional items, ICT and telecommunications, utilities, cleaning, catering and travel services, training and consultancy services and professional services (legal, audit and investment management).
As in previous years, we used a risk-based approach to assess the likelihood of modern slavery within our supply chain. This scoped-in suppliers using both qualitative and quantitative criteria, including the origin of a product, the location and method for providing a service and the value of a product / service. We also scoped-in a number of suppliers providing products and services in relation to our office move in 2021. We used a questionnaire to identify and assess potential modern slavery risks relating to these suppliers. We received a satisfactory and timely response from all scoped-in suppliers.
We will repeat this risk-based approach in 2022, focusing again on new suppliers and any others we determine meet our qualitative risk criteria. The latter will include most suppliers to MPL. In addition, we will use our new procurement and contract management policy to ensure more pro-active due diligence of our suppliers in this and other areas. This will extend to providers of third party products offered by the Group.
The questionnaire returns from all suppliers are reviewed and recorded. If we were to identify a medium or high-risk supplier or activity within our supply chain, we would work with the organisation to take remedial action or, if more appropriate, to take steps to remove the organisation from our supply chain. There have been no instances to date where such action has been needed.
The Company Secretary attended external training events about modern slavery, potential reforms to the Act and modern slavery statements in 2021. He will make recommendations, as required, to respond to the modern slavery bill proposed in The Queen’s Speech in May 2022.
A training module about modern slavery will be rolled out to colleagues in 2022, following the launch of our new procurement and contract management policy. This will be supported by a modern slavery policy. In addition, colleagues will be required to complete the annual training module about ‘whistleblowing’, which supports our existing policy on the reporting procedures within MDDUS.
This statement applies to the MDDUS Group, including its subsidiaries. It is published to the front page of the MDDUS website and is filed, on a voluntary basis, with the modern slavery registry launched in 2021.
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23 June 2022