Modern Anti-Slavery Policy

SECTION 1 – 2022 ANTI-SLAVERY & HUMAN TRAFFICKING STATEMENT

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes The Nature Clinic’s actions to understand and eliminate all modern slavery risks and to put in place steps aimed at ensuring there is no slavery or human trafficking within our own business and/or our supply chains. 

The Nature Clinic Ltd are committed to acting ethically and with transparency in all our business operations and to ensuring effective processes and controls are in place so that all our employees, business partners and extended communities are treated with respect and dignity and that we do not engage directly or indirectly with slavery or human trafficking.

Our support of human rights – The Nature Clinic Ltd supports human rights across our global operations and value chain. The UN Guiding Principles on Business and Human Rights provide a framework to help us identify and prioritise our human rights risks and impacts. Proactive human rights due diligence is an ongoing process, and we have policies, processes, training, and systems in place to identify, assess, monitor, and mitigate or eliminate actual or potential human rights impacts.

We have conducted a Human Rights Assessment (HRA) based on the methodology outlined by the UN Guiding Principles on Business and Human Rights, the global standard for HRAs. Through the HRA process, we assessed human rights risks and impacts across our operations, including our policies and procedures, as well as our supply chain, manufacturing, and retail operations. The HRA has provided us with a framework to help identify and prioritize human rights risks and impacts, and to identify key actions for improvement. More information on the UN Guiding Principles can be found here: www.unglobalcompact.org/library/2.

The Nature Clinic Ltd are required by the UK Modern Slavery Act 2015 to disclose publicly the steps they are taking to identify and eradicate forced labour and human trafficking from their supply chains. The following describes The Nature Clinic’s relevant commitments and initiatives:

 

SECTION 2 – ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS

The Nature Clinic Ltd sources ingredients and materials from around the world to manufacture our products. Our teams work diligently to source ingredients responsibly and with attention to potential impacts on people and environment. We aim to continuously strengthen our sourcing practices while remaining sensitive to the local communities in which we operate.

Our Sourcing team is part of our Procurement function and works closely with the Research and Development (R&D), Sustainability, Packaging, and Legal functions. The team establishes, implements, and monitors environmentally and socially responsible and ethical sourcing practices to ensure that performance is aligned with our goals and objectives. We collaborate with, suppliers, industry groups, and peers to continuously advance our practices.

 

SECTION 3 – POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING

Our Supplier Code of Conduct (“Supplier Code”) is the foundation of our Sourcing programme. The Supplier Code (along with The Nature Clinic’s Human Rights Policy) outlines our expectations for suppliers with respect to human rights, the rights of indigenous peoples, and local communities, as well as the workplace.

In conjunction with our standard purchasing contracts, the Supplier Code requires that suppliers be in full compliance with all applicable governmental, legal, regulatory and professional rules and regulations governing minimum wages, work hours, overtime compensation, hiring, occupational safety, forced and/or child labour and biodiversity. The Supplier Code is organised into three sections:

• Engage in lawful and ethical business practices.
• Promote a respectful, fair, and diverse workplace.
• Provide a safe, healthy workplace and protect the environment and community.

The Supplier Code covers areas including confidentiality and privacy, fair competition, child labour, and forced labour, among others. This specifies that The Nature Clinic Suppliers must not employ child labour. The term “child” means any person employed under the age of 16 or under the minimum age for employment in the country, whichever is greater. The Nature Clinic suppliers employing young workers (workers above the minimum age of employment but under the age of 18) must comply with applicable laws and regulations regarding hours, compensation and must avoid conditions or restrictions that could be harmful to their morals, health, safety and development.

The Supplier Code also specifies that The Nature Clinic Suppliers must not use or benefit from any form of human trafficking, or forced or compulsory labour of any kind, be it prison, bonded, indentured or otherwise. Furthermore, mandatory overtime is not permitted, and workers must be allowed to leave their employment after giving reasonable notice. Imposing monetary fines, withholding identity papers (such as passports), work permits, remuneration or requiring recruitment deposits or other constraints as a condition of employment, is not allowed.

In addition to the Supplier Code, our Supplier Sustainability Guidelines provide suppliers with practical actions they can take to manage the environmental and social impacts of their own operations. These guidelines help them to build on the foundation of the Supplier Code requirements and move towards implementing improved practices in sustainability.

 

SECTION 4 – SUPPLIER EVALUATION AND MONITORING

We monitor our suppliers to ensure adherence to the Supplier Code and pay careful attention to potential risks. We conduct risk assessments and perform due diligence on select direct and indirect suppliers. We also monitor supplier performance and implement corrective action plans as needed.

 

SECTION 5 – INTERNAL ACCOUNTABILITY AND TRAINING

We promote a culture of uncompromising ethics and integrity with standards to help us uphold our principles and ideals. We expect our employees and business partners to conduct business in compliance with applicable laws and regulations and with the high ethical standards and policies set forth in our Code of Practice.

 

SECTION 6 – CONDUCT (“CODE”) AND SUPPLIER CODE

Our Code helps to protect our reputation as an ethical corporate citizen. Newly hired employees are required to sign an acknowledgement that they have received, read, and will comply with the Code. In addition, annually, employees above certain levels are required to complete Ethics and Anti-Bribery and Corruption trainings and acknowledge the Code.

We all have responsibility to conduct business the right way. We promote a speak-up culture and provide a mechanism for reporting suspected misconduct. We will not tolerate retaliation against anyone who in good faith raises questions or concerns about a potential violation of the law, our Code, or Company policies, or who assists in an investigation of a reported violation. Retaliation in any form is itself a serious violation of our Code and is strictly prohibited. Acts of retaliation or potential retaliation should be reported immediately. Anyone found to have retaliated against an individual will be subject to disciplinary action, up to and including termination of employment.

 

Co-Founders & Directors

The Nature Clinic Ltd

Date: 01/02/2023

 

Last updated: 1^st February 2023