The MDDUS is a mutual organisation providing healthcare professionals across the UK with access to indemnity, assistance and support. A private company limited by guarantee, MDDUS is the trading name of the holding company of the Group. There are three wholly owned subsidiaries: MDDUS Insurance Limited, an insurance company; MDDUS Education Limited, a risk and training company; and MDDUS Property Limited, which oversees the management and performance of the investment property portfolio.
MDDUS is not a listed company, but it aims to comply with the Association of Financial Mutuals’ UK Corporate Governance Code: an annotated version for mutual insurers. 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 MDDUS has a firm belief that there is no circumstance where slavery, forced labour and human trafficking are acceptable in any form.
Internal risks and processes
The professional-service nature of MDDUS business is considered to expose the company to a low level of risk in relation to the occurrence of slavery and human trafficking. Internal methods, in particular, our human resource procedures and pre-employment checks, help ensure that we comply with The Act. The MDDUS is committed to fair pay and no one working within the MDDUS earns less than the living wage. In 2017, following consultation with staff, the MDDUS began the process of increasing its health and wellbeing offerings to staff. The MDDUS therefore believes that the area of highest risk for the organisation is in its supply chain.
The reputation of the MDDUS is built on trust and integrity and, as such, the MDDUS has particular expectations from staff members, industry partners and organisations with which it conducts business. The MDDUS selects and forms relationships with partners who demonstrate a compatible ethos and approach in recognising that people involved in any level of business process should be treated with dignity and respect.
Identification of risk in our supply chain
The MDDUS has a varied supply chain which includes purchase of a range of products and services, including: professional services (legal and audit), office equipment and supplies, cleaning services, vehicle purchase, ICT and telecommunications, utilities, training & consultancy services, promotional items, catering and travel services.
To assess compliance with The Act internally and from the supply chain, The MDDUS has undertaken a gap analysis. Moving forward, the MDDUS will adopt a risk-based approach to assess the likelihood of the existence of modern slavery within its supply chain. Criteria will include factors such as origin of products and the location and method from which services are provided. This will enable classification of suppliers and identification of potential risk areas for modern slavery.
Our action plan to compliance
In 2017, an action plan was produced which identifies areas for progress, including; formation of a Modern Slavery Act Working Group; risk assessing and mapping the supply chain to first-tier suppliers in the first instance, identifying any areas of higher risk for modern slavery, the development of a ‘Supplier Code of Conduct’ and identifying any relevant training opportunities.
The working group has drawn on stakeholders from across the organisation to ensure appropriate identification of risk and holistic embedding of the spirit of The Act. Where we identify a high-risk supplier or activity, we may work with the organisation to rectify, or take steps to remove the organisation from the supply chain if this is the most appropriate course of action.
This statement applies to MDDUS Group and all subsidiaries.
Dr Brendan Sweeney