This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and outlines the steps Gardamed Limited takes to prevent modern slavery and human trafficking within our operations and supply chain.
1. Our Business
Gardamed is a UK-based distributor of Class I medical devices, supplying healthcare organisations, private customers and commercial partners. Our operations are supported by a certified ISO 9001 quality management system, ensuring strong governance, documented processes, and effective supplier oversight.
2. Our Supply Chain
Our supply chain is direct and transparent, consisting of established medical device manufacturers located in: Italy, Portugal, Israel, The Netherlands.
These countries have robust labour laws, strong regulatory frameworks, and low modern slavery risk profiles. We maintain long-term relationships with all manufacturing partners and ensure ongoing compliance with applicable regulations.
3. Our Commitment
Gardamed has zero tolerance for:
- Forced or compulsory labour
- Human trafficking
- Child labour
- Bonded or servitude-based labour
- Any form of labour exploitation
We expect all suppliers and partners to uphold these standards and comply with the Modern Slavery Act 2015 or equivalent national legislation.
4. Policies & Governance
To support our commitment, we maintain:
- A Modern Slavery & Human Trafficking Policy
- A Supplier Code of Conduct outlining ethical expectations
- ISO 9001-aligned supplier qualification and review procedures
- An Anti-Bribery & Corruption Policy
- A Whistleblowing Policy allowing confidential reporting of concerns
Policies are reviewed regularly and updated as necessary.
5. Supplier Due Diligence
We undertake due diligence with each supplier, including:
- Verification of regulatory compliance (CE, UKCA, ISO standards)
- Assessment of labour practices and ethical declarations
- Review of suppliers’ own modern slavery statements where applicable
- Ongoing performance and compliance monitoring
Non-compliant suppliers are investigated and may be suspended or removed from our supply chain.
6. Risk Assessment
Based on product type, supply geography, and supplier structure, we assess our modern slavery risk as low.
Manufacturers operate in regulated medical device environments and in jurisdictions with established protections for workers. We continually monitor risk factors and government guidance to ensure our risk assessment remains current.
7. Training & Awareness
Personnel with responsibility for procurement, supplier management, and quality assurance receive training and guidance on:
- Identifying signs of modern slavery
- Understanding supply chain risks
- Escalation and reporting procedures
8. Reporting Concerns
Gardamed encourages internal and external stakeholders to report any concerns regarding unethical labour practices. All concerns are taken seriously, investigated promptly, and escalated where required.
9. Continuous Improvement
We are committed to strengthening our approach through:
- Annual supplier reviews
- Enhancing transparency and documentation
- Continuous improvement of our MSAT (Modern Slavery Assessment Tool) responses
- Alignment with NHS Supply Chain ethical procurement requirements
10. Approval
This statement has been approved by the Director of Gardamed and will be reviewed annually.
Signed:
Mandy Wright
Director, Gardamed Limited
Date: 28/11/2025
