Modern Slavery Statement

Introduction:

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) and sets out the steps taken by Prima Dental in preventing modern slavery and human trafficking in its business and supply chains. This statement covers the calendar year 2023 (also Prima Dental’s financial year).

Our structure, business and supply chains:

With over 260 employees at our production facilities in the UK, alongside a sales subsidiary in India and joint venture partnerships in Brazil and Hong Kong and China, we produce over 50 million carbide, diamond and steel dental burs each year. We supply to more than 90 countries with growing markets in the USA, Europe, Middle East and Asia-Pacific.

We strive for ‘the constant pursuit of better’. We aim to deliver this by living our six values, which are Customer Service Excellence; Attention To Detail; Accountability; Integrity; Continuous Improvement and Collaboration. These values demonstrate our commitment to act ethically and with integrity in all our relationships.

To support our day-to-day operations we procure a wide range of materials and services required for both manufacture and business operations, such as office supplies. We engage hundreds of suppliers making our end-to-end supply chains extensive and complex.

Risk Assessment & Management:

At Prima Dental we recognise that, whilst we are a business with our headquarters in the UK, Modern Slavery is a complex, global issue which affects our overseas partnerships as well as our supply chain. The two principal areas of focus in our business are at frontline level, in safeguarding colleagues (and anyone else who comes through our facilities), and in our supply chain.

In terms of our business operations, we promote a high performance and inclusive culture whereby we encourage any colleague to feel comfortable to approach any senior manager to raise any issues. We have a robust complaints procedure which covers the reporting of mis-treatment and/or exploitation concerns. The senior management regularly liaise with all teams to encourage and listen to feedback for how to improve practices, keeping the team fully updated with the outcome of new ideas presented. We feel confident that we monitor our operations closely , including our workforce, and would spot any negative signs of behaviour.

We believe colleagues are well placed to identify and deal with Modern Slavery through the training we have undertaken. Colleagues are trained to recognise and report signs of abuse. We believe the rigour of this system materially mitigates the risk of modern slavery from either going undetected or being inadequately dealt with. The front-line risk is further controlled by the support, training and infrastructure in place for all colleagues to be able to raise concerns, via their line manager or the People Team, in confidence,

Prima Dental has a closely knit team in the UK spread over three facilities. It is within this context that we have identified that the most significant risk of modern slavery within our business is in our group supply chain.

We have conducted an initial ‘desk-top’ analysis to identify where our risks are and in line with this, the Senior Management Team has devised a plan to progress, through our wider supply chain and business partners operations, conducting a risk assessment with an action plan to address any areas of concerns or weakness. Specifically for 2024 our aim is to:

Establish a risk assessment process for our supply base with a focus on country risks and supply experience as well as welfare provisions for workers included.
Implement a Supplier Questionnaire with our UK supply base. We will check awareness levels in our business partners and share relevant material to help support any gaps in knowledge to encourage widespread focus through business operations of this atrocious crime.
Utilise the Supplier Questionnaire for all new suppliers, as part of our due diligence process.

During this process any supplier identified as medium or high risk will be prioritised for additional assessment and mitigations/remedies agreed. If an issue were to be identified or arise we would first seek to address through collaboration with our supplier where there is realistic prospect of remedy/reform. However, we would not hesitate to immediately cease dealings with a supplier if there showed no desire to work with us to improve processes. At Prima Dental, we acknowledge that risks need to be monitored, reviewed and adapted to keep ahead of any new ways that exploiters use to operate as we increase our learnings.

Measuring effectiveness:

Following the launch of our Preventing Modern Slavery policy in October 2023; for 2024 we are committed to the following:

Maintaining a qualitative approach by assessing our business for areas most susceptible to the risks of modern slavery and human trafficking, and identifying, undertaking and continuously building on appropriate actions that will have the biggest impact on reducing and ultimately eliminating modern slavery from happening in our business.
Key to our progress, will be encouraging collaboration between all stakeholders in our supply chain to increase their work to help eliminate Modern Slavery. Sharing key learnings, including instances found highlighting potential infiltration avenues for exploiters, help us understand and strengthen all of our processes as part of our plan to implement preventative measures.
We will review the development of KPIs in 2024. We understand that producing KPIs can help us view the level of exposure Prima Dental has with regards to the risk of modern Slavery and will link the KPIs to the risk assessment work. One of the aims for the creation of the KPIs is to analyse them over the next two years to check our progress in raising awareness and preventing Modern Slavery in our supply chain.

Relevant Policies:

We are in the early stages of creating policies and processes to take proactive action to implement steps to set out our approach.

So far, we have developed the following polices which set out our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Preventing Modern Slavery, Labour Exploitation and Human Trafficking Policy

We launched our policy In October 2023 which will be reviewed annually. This reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and Human Trafficking is not taking place anywhere in our operations. The policy applies to all employees and persons working for us in any capacity. It explains the description of Anti-slavery and Human Trafficking, the reason for the policy, and to whom the policy applies. It also clearly sets out how to report any concerns about Anti-slavery or Human Trafficking.

Whistleblowing & Grievance Policies

We encourage all our colleagues, customers and our supply chain business partners to report any concerns. This includes any circumstances that may give rise to an enhanced risk of slavery or Human Trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. We have had no reports regarding Anti-Slavery and Human Trafficking during the period covered by this statement.

Training:

Training and raising awareness are absolutely fundamental to ensure all our colleagues understand the importance of this issue, know the practical signs of modern slavery and how it can impact our business and those in our supply chain.

Upon the launch of our Modern Slavery Policy in 2023 the following training was undertaken:

The Executive Team attended a ½ day training and awareness session with our third-party Ethics partners/ advisors.
All colleagues undertook on-line training titled “Business Compliance – Modern Slavery”.

For 2024 we will undertake to do the following:

All new starters will be given a copy of our policy and will be expected to complete the on-line training titled “Business Compliance – Modern Slavery” as part of their onboarding.
We will ensure that learning materials including case studies in relation to preventing modern slavery will be placed within our Company Intranet that all colleagues have access to.
On National Anti-Slavery Day in October 2024 we will raise awareness of modern slavery risk via a Social Media campaign

We abhor the practice of modern slavery – it is contrary to Prima Dental’s purpose and the values we live daily. We are committed to continuously developing and strengthening our approach, each year, to make meaningful progress and a positive impact with our stakeholders towards eradicating this crime.

This statement has been approved by the Executive Leadership Team of Prima Dental.

Alun Jones
Group Managing Director
31 January 2024