MDDUS 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 the investment property portfolio.
The Board is committed to a high standard of corporate governance. As one of the largest members of the Association of Financial Mutuals (AFM), MDDUS must apply the principles of the AFM Corporate Governance Code (January 2019). The MDDUS operates only within the UK and Channel Islands and complies with all relevant company law.
The Act defines modern slavery as “slavery, servitude, and forced or compulsory labour” including “human trafficking”. The Board believes firmly that there are no circumstances in which it is acceptable to support and / or encourage slavery, forced labour and / or human trafficking.
Internal risks and processes
We believe that the professional-service nature of our business exposes us to a lower risk of the occurrence of slavery, forced labour and / or human trafficking. 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, and 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 of a business process should be treated with dignity and respect.
MPL is identified as a higher risk because of the nature of some property management work, and the fact that our relationship with these services is one-step removed. We work closely with our main supplier, Daniel Watney, who are committed to ensuring there is transparency in their business and approach to tackling modern slavery throughout their supply chains. Daniel Watney’s own statement 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.’
Our own standard contracts for the supply of goods and services include terms and conditions relating to the Act.
Identification of risk in our supply chain
We have a varied supply chain, which includes the purchase of a range of products and services – for example, professional services (legal, audit and investment management), office equipment and supplies, cleaning services, ICT and telecommunications, utilities, training and consultancy services, promotional items, catering and travel services.
As in previous years, we used a risk-based approach to assess the likelihood of slavery, forced labour and / or human trafficking within our supply chain. This considered, amongst other things, the origin of a product, the location and method for providing a service and the value of a product / service. We used a questionnaire to review our scoped suppliers to identify and assess potential risk areas. We received a satisfactory and timely response from our suppliers.
We will repeat this risk-based approach in 2021, focusing in particular on new suppliers. In addition, we plan to use the opportunity of introducing a new procurement and contract management framework to enable more pro-active due diligence of our suppliers in this and other areas.
Where we identify a high-risk supplier or activity within our supply chain, we work with the organisation to take remedial action or, if more appropriate, take steps to remove the organisation from our supply chain. There have been no instances to date where remedial action has been needed.
A training module will be rolled out in 2021/22 to advise all colleagues about the Act, including how to identify and report potential incidents of slavery, forced labour and / or human trafficking. In addition, colleagues will be required to complete a training module about ‘whistleblowing’, which will support our existing policy on the reporting procedures within MDDUS.This statement applies to the MDDUS Group, including its four wholly owned subsidiaries.
25 June 2021