i. Leanvation Worldwide Limited is committed to upholding an ethical labour policy in- line with its legal and moral obligations. The standards are maintained within the Company and the Suppliers within the Company’s supply chain.

ii. These ethical standards cover:
a. Child labour
b. Forced or compulsory labour
c. Freedom of association and right to collective bargaining
d. Discrimination
e. Health and Safety
f. Working hours
g. Remuneration
h. Supplier relationships

iii. As part of our commitment to quality and our ISO 90001 standards we continually assess and monitor our own performance and process controls and also those of our suppliers. Our aim is to ensure that standards are continuously improving.

iv. The organisation commits to making available sufficient resources for the implementation of this policy.


1. Introduction: As a manufacturer of Healthcare Products, Leanvation Worldwide Limited recognises its obligation to provide our customers with high quality, professional goods and services at a competitive price whilst ensuring that at no point is any person in any part of the supply chain exploited or treated in a way that breaks relevant employment legislation or those standards which Leanvation deem suitable and appropriate. Leanvation are fully aware of the responsibilities we bear to all parties involved in each of the stages involved in producing our products and have developed this policy to outline the standards that we, and ultimately all stakeholders involved with the business, should seek to adhere to. Leanvation Worldwide Limited shall show a preference, where appropriate and possible, to suppliers with higher labour standards.

2. Aims: The aim of this policy is to promote understanding and awareness of employment laws and ethical standards. By detailing our labour standards to all parts of our supply chain, we hope to develop better ethical standards by motivating our suppliers to adhere to it. It also describes the standard required of potential future suppliers.

3. Objectives: The Leanvation Worldwide Limited Labour Standards objectives are as follows:
a. To become a progressive ethical company and comply with the ETI Base Code
b. Key Suppliers, as denoted by the Leanvation Quality Manual, should have full compliance with the Ethical Trading Initiative (ETI) Base Code.
c. All suppliers should fully comply with the ETI Base Code.
d. Encourage parties in our supply chain to develop their own labour standards system and provide help and support to allow them to do this.

4. Policy Statement: The Leanvation Worldwide Limited policy in relation to labour standards as relevant to the organisation itself, contractors, sub-contractors, suppliers and any other parties engaged through the supply chain is as follows:
a. We shall comply to all Employment Laws relevant to our business
b. We comply to the Health and Safety Act 1974 – as outlined by the Employee Handbook
c. We comply with all other Employment legislation – as outlined by the Employee Handbook.
d. Our compliance with the above is kept up to date through regular reviews
e. Leanvation will always seek to operate in compliance with the ETI Base Code. This demonstrates compliance with the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labour Organisation Declaration on Fundamental Principles and Rights at Work, in accordance with international, national and local law and practice.
f. We shall encourage all suppliers and contractors to adhere to the Ethical Trading Initiative as part of their respective contracts.

5. Management Representative: The management representative assigned the responsibility of implementing an effective Labour Standards Assurance System (LSAS) for Leanvation Worldwide Ltd is Dr Jonathan Day. The responsibilities of the Management Representative are as follows:
a. To develop procedures to meet policy requirements;
b. To communicate labour standards issues to senior management;
c. To liaise with companies in the supply chain to undertake labour standard status reviews;
d. To set objectives and targets for labour standards assurance with plans for training, auditing and required action;
e. To liaise with companies in the supply chain to implement a plan of action to meet objectives;
f. To regularly review and improve the Labour Standards policy;
g. To implement training for staff involved with the LSAS;

6. Roles & Responsibilities: Given the size of the company and the number of companies in the supply chain, it is adequate for Dr J Day to undertake the main responsibility of the LSAS. The Management Representative shall liaise with the management board to develop the LSAS and present any developments at regular intervals to the board. Members of staff involved with the LSAS shall be identified using the training records system and skills matrix. Target setting for staff involved with the LSAS shall be incorporated into the half-yearly and yearly personnel reviews as relevant Resources relating to the LSAS will be available to all involved staff via the Leanvation Worldwide Limited intranet.

7. Labour Standards Status Review: Leanvation Worldwide Limited commit to undertaking a comprehensive Labour Standards Status Review; when contracting a new supplier and at regular routine visits to suppliers, to ensure that labour standards throughout our supply chain are satisfactory and continually improving. We recognise that if any contractor or sub-contractor were found to be using unethical or illegal labour programs, this would have a profound impact on the reputation and integrity of the company. The procedure for conducting a Labour Standards Review can be found in section 20 of the Quality Manual. The timescale of the Labour Standards Status Review is subject to change, given the findings from previous reviews, as deemed appropriate by senior management during a Quarterly Management Review.

8. Legal Requirements: Leanvation Worldwide Limited commit to r remain up to date with changes to relevant employment legislation through the use of due diligence and use of consultative professional support. Relevant employment legislation with regards to Leanvation Worldwide Limited direct operations is outlined in the Employee Handbook and is signed by all employees once read and understood.

9. Objectives, Targets & Programmes: Leanvation Worldwide Limited commit to developing a Corrective Action Plan (CAP) as part of the Improvement Request form (IR) following each Labour Standards Status Review. The IR/CAP will be reviewed by senior management during the routine quality review, in line with the Quality Manual, to determine whether the company is on target to reach their objectives and to ensure these objectives are still appropriate. This will ensure that all relevant personnel will be kept up to date with the development of the LSAS programme.

10. Competence, Training & Awareness: Leanvation Worldwide Limited commit to the training of relevant staff in order to be competent with handling the labour standards programme. Relevant staff for Leanvation Worldwide Limited are those involved in procurement and new product development. Persons involved with the LSAS should:
a. Have a good understanding of how Leanvation Worldwide Limited operates with knowledge of the supply chain
b. Be in a position to contact suppliers and build a relationship with them
c. Be trained in the LSAS requirements
Training for the LSAS is implemented as part of Leanvation Worldwide Limited’s training checklist, which keeps a record of the training levels of all the staff at the company. Training reviews and development plans for the LSAS will be included as part of the current training system.

11. Communications: Since the LSAS is embedded into the current Leanvation Quality System, the existing training systems, quality systems and recorded communication will be used to address LSAS issues. We will use the IR system to log and monitor any adverse allegations, complaints or alerts relating to the LSAS.

12. Documentation & Records: Documentation and records in relation to the LSAS shall be kept using standard document and record keeping procedures in line with other Leanvation Quality Documents.

13. Operational Control: For the direct operation of the company, the Employee Handbook documents the procedures involved with controlling the labour standards of the company and addressing any risks or breaches of this policy that may be posed. The senior management of Leanvation Worldwide Limited have identified two critical control points for labour standards in the supply chain; supplier approval and supplier visits.

14. Supply Chain Management: Leanvation Worldwide Limited commit to monitoring and maintaining the labour standards in the company’s supply chain through the distribution and communication of the company’s labour standards policies along with the on-going assessment of whether these standards are being met. This will occur using assessments at the control points. New suppliers must meet Leanvation Worldwide Limited’s initial approval that outlines the standards to which the supplier is expected to maintain as part of their contract. These standards comply

fully with those required by the LSAS. Reviews shall be taken at routine visits to suppliers to ensure they continue to comply fully with the LSAS. The findings of supplier visits shall be noted in the routine quality review.

15. Emergency Response: Leanvation Worldwide Limited have identified aspects of the ETI Base Code that are of particular importance for meeting minimum levels of labour standards. Sections 1.1, 1.2, 4.1 and 9.1 are regarded by Senior Management of GBUK as statements that justify emergency response. Emergency Response comprises a request for a written Corrective Action Plan within 14 days that is approved by all parties involved. Should this Corrective Action plan be deemed unacceptable then resourcing of production from within Leanvation Worldwide Limited’s existing supplier base shall be implemented within 30 days of the initial breach of the above minimum labour standards.

16. Performance Monitoring & Measurement: Leanvation Worldwide Limited commit to monitoring the performance of the LSAS assessing the progress against the latest CAP where appropriate and setting relevant targets, in addition to those stipulated in this policy, to ensure the progression of the LSAS against our objectives. Progression of parties in the supply chain shall be measured against the level of compliance with the ETI Base Code.

17. Corrective Action: The current IR quality system will be used to document improvements from labour standards audits.

18. Management Review: Senior management will formally review the labour standards programme during the routine Management Review process.

19. ETI Base Code: The can be found at:
http://www.ethicaltrade.org/sites/default/files/resources/ETI%20Base%20Code%2C%20En glish.pdf