1. Scope
This policy applies to all Osteotec employees and all parties in Osteotec’s supply chain.
2. Purpose
This policy outlines our commitment and approach to upholding minimum labour standards. We believe that it is important to maintain high levels of ethical standards in line with our values of prioritizing People, Integrity & Accountability and Commitment to Continuous Improvement. Upholding these standards are also important for maintaining and protecting Osteotec’s reputation, mitigating risks to continuity of supply and attracting and retaining talent.
This Policy is informed by, among other things, the International Bill of Human Rights, the Equality Act 2010 (as amended), Bribery Act 2010, Modern Slavery Act 2015 (as amended) and the Ethical Trading Initiative Base Code.
3. Commitment to Labour Standards
3.1. We expect our suppliers to maintain appropriate ethical standards and will take all reasonable steps to establish the ethics and employment standards of our suppliers in line with this policy and our Anti-Slavery Policy.
3.2. So far as possible, we will only source products from suppliers who maintain appropriate ethical standards for the area in which they operate. Where shortcomings in supplier practices are identified, this may result in Osteotec requiring corrective action by the relevant supplier or the termination of Osteotec’s engagement of that supplier.
4. Minimum Labour Standards
4.1. Freedom of association and collective bargaining: Osteotec recognises that workers have the right to form trade unions of their own choosing and to bargain collectively, and will comply with all applicable employment legislation.
4.2 Forced and compulsory labour: Osteotec shall not engage in or support the use of forced or compulsory labour, or bonded or involuntary prison labour. All work must be provided voluntarily, and conducted only through freely agreed and fully documented employment terms. Employees must be free to leave upon reasonable notice without fear of any form of abuse or reprisal.
4.3. Child labour: Osteotec shall not engage in or support the use of child labour in any form. We determine this type of labour to be any labour which:
- is mentally, physically, socially or morally dangerous and harmful to children; and/or
- interferes with their schooling.
All employees engaged by Osteotec and its suppliers must. Be of appropriate age as defined by applicable laws. If young workers are engaged for the purpose of work experience, then a suitable risk assessment will be carried out to ensure they are not exposed to any harmful conditions and their working day is limited to 8 hours.
4.4. Working conditions: Osteotec is dedicated to providing a safe and healthy working environment and shall take effective steps to prevent potential accidents and injury to employees’ health by minimizing, so far as reasonably practicable and in co-operation with employees, the causes of hazards in the workplace. All employees will be provided with appropriate health and safety training as part of their induction process, and provided with ongoing training throughout their employment. Osteotec’s full Health & Safety policy is set out in the Employee Handbook and contains maintained procedures for handling emergencies, such as fires and first aid events. Osteotec’s Talent, Learning and Development Manager is responsible for the organization and implementation of Osteotec’s Health & Safety policy.
Osteotec acknowledges that access to clean sanitary facilities and drinking water is a fundamental human right, and will be provided to all employees.
4.5. Working hours and remuneration: Osteotec will comply with all applicable laws and industry standards on working hours, holiday entitlements and remuneration. Osteotec’s normal working hours do not exceed 48 hours per week, overtime hours will not exceed 12 hours per week and employees will receive at least 24 hours of rest per week. Osteotec honours the National Living Wage, and expects its suppliers to do the same, or such equivalent living wage as may apply in their jurisdiction. Clear terms of employment are provided to employees before they enter employment, and Osteotec ensures that all employees have the legal right to be employed in the UK prior to their employment commencing.
4.6. Reporting grievances: Osteotec maintains a Disciplinary Policy and a Whistleblowing Policy which sets out the process for employees to report employee grievances and any concerns they may have relating to the conduct of the business in accordance with this policy, and any other Osteotec policies. Employees are also encouraged to raise any concerns they have with their line manager or the Group General Counsel. Any suppliers who have concerns should raise these directly with the Group General Counsel (legal@osteotec.co.uk).
4.7. Equality, Discrimination and Human Rights: Osteotec operates with inclusion and respects diversity, treating all employees equally. We maintain an Equal Opportunities, Discrimination, Harassment and Anti-Slavery Policy setting out in more detail our commitment to this. Osteotec shall not engage in or support any discriminatory practices in hiring, remuneration, access to training, promotion, termination or retirement based on race, national or social origin, caste, religion, gender, sexual orientation, political affiliations, age or other conditions that could give rise to discrimination.
5. Review of this Policy
The Group General Counsel is responsible for the ongoing administration and maintenance of this policy. This policy will be reviewed annually by the Group General Counsel in line with legislative changes and industry best practice to ensure that it is both up-to-date and effective. Any updates reviewed and approved by Osteotec’s Board of Directors.
6. Accessibility and implementation
6.1. The policy is publicly available at all times via our website www.osteotec.co.uk.
6.2. It is communicated to all Osteotec employees during their induction process, and training is provided when any updates are made to the policy. This is recorded in each employee’s induction and training records.
6.3. All Osteotec suppliers are sent a copy of the policy as part of our supplier onboarding process, and receive a copy of the updated policy on an annual basis.
6.4. Sufficient resources are made available for the review, implementation and improvement of this policy and all related policies and procedures.