Modern Slavery Statement
This statement has been published pursuant to section 54 of the UK Modern Slavery Act 2015, and applies to Mindray (UK) Limited, Mindray’s ultimate parent company, Shenzhen Mindray Bio-Medical Electronics Co., Ltd. and its subsidiaries (“Mindray Group”). It sets out the steps taken by the Mindray Group during the financial year ended 31 December 2022 to address modern slavery and human trafficking in its business and supply chains. Any reference to “Mindray” herein refers to the Mindray Group as described in this paragraph.
Mindray is committed to fully complying with all applicable labour and employment laws, rules and regulations and working to mitigate the risk of human trafficking in our business and supply chains. This Statement is consistent with the Mindray Code of Business Conduct and Ethics and Mindray core values of treating all people with respect and dignity. This Statement is available at https://www.mindrayuk.com/modern-slavery-statement/
Introduction
Mindray takes its responsibility as a positive global corporate citizen to heart. Mindray is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and imposes the same high standards on its suppliers. At Mindray we are committed to improving our practices to combat slavery and human trafficking.
Mindray was founded on the belief that every life is valuable. As expensive and complex technology still remains out of reach for the majority of people, we are striving to improve healthcare by developing and sharing medical technologies with the world. In doing this we can provide better care for more people, not just with our customers in mind but with humanity in mind.
Mindray’s Business
Mindray is one of the leading global providers of medical devices and solutions. Headquartered in Shenzhen, P.R.China, Mindray has 52 overseas subsidiaries in approximately 40 countries and 21 subsidiaries and approximately 30 branches in the territory of P.R.China (excluding Hongkong, Taiwan and Macau). To find out more about the nature of our business, please click here.
Our Supply Chains
In order to produce and distribute our medical devices and solutions, we work with a range of suppliers involved in the procurement of raw materials, services, logistics, as well as product transportation to our warehouses, agents, distributors, and end customers.
Our suppliers come from all over the world. We work mainly with Chinese suppliers, but also with suppliers from the United States, Germany, Sweden, Finland, the United Kingdom, Japan and other countries.
Based on the long-life cycle of Mindray's products, we expect to maintain long-term cooperative relationships with suppliers. More than 45% of suppliers have cooperated with Mindray for more than 10 years. In the process of supplier introduction and cooperation, suppliers are continuously reviewed and trained to achieve the goal of long-term development in harmony with each other.
Our Policies
Mindray Code of Business Conduct and Ethics is in the process of being updated to better emphasise its commitment to combatting the risk of modern slavery in our operations and supply chain; in this respect, we have also implemented our Combating Trafficking in Persons Policy, which applies to the Mindray Group except Mindray DS USA Inc., and our Mindray DS Combating Trafficking in Persons Policy, specifically tailored and applicable to our US legal entity, Mindray DS USA Inc.
To standardize the anti-discrimination, anti-harassment and anti-bullying management of the Group, we apply for establishing the "Anti-discrimination, Anti-harassment and Anti-bullying Policy" in October 2022.
Due Diligence
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk, we have procedures in place to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
In 2022 Mindray have enhanced its “Due Diligence Questionnaire for Business Associates” (e.g. distributors) that, among other things, addresses specifically Modern Slavery and Human Trafficking risks.
On-boarding, auditing and appraising our suppliers
New suppliers are subject to due diligence checks in the form of: (a) a due diligence questionnaire including responsible business practices, and (b) an on-site audits.
As part of the on-boarding process Mindray has also introduced a “Supplier Compliance Statement” that all suppliers must execute before performing a supply contract. The statement in question covers, among other things, Modern Slavery and Human Trafficking risks. Moreover, suppliers must complete a “Self-evaluation Form” which embeds specific indicators in relation to Modern Slavery and Human Trafficking risks.
The on-site audit is managed by the Procurement Team, who will conduct the audit, and record the audit findings according to Mindray’s scoring standards. Conducting an on-site audit is Mindray’s standard approach, however at times Mindray’s Procurement Team may decide not to conduct an on-site audit based on the supplier’s risk-category and other factors.
The on-site audit includes questions to evaluate to what extent the supplier protects employees, including: (i) safety measures and protective equipment, (ii) reporting and records of any incidents or injuries, (iii) prohibition of child labour and compliance with local labour law, (iv) a working environment free from discrimination, (v) communication of employees’ rights, (vi) emergency planning, (vii) environmental management systems, (viii) compliance with environmental laws, (ix) waste management, (x) actions to monitor and minimize negative environmental impacts. Suppliers whose audit results are satisfactory can be introduced as qualified suppliers; whilst suppliers whose audit results are conditional upon the implementation of a rectification plan, will need to demonstrate compliance before being approved. The audit team tracks suppliers’ rectification efforts through an "Improvement Evaluation Form".
Since 2019, Mindray European subsidiaries (including Mindray (UK) Limited), have been using Lexis Diligence, a web-based interface featuring global news, business, legal, public records and regulatory content, to conduct due diligence on third parties.
Suppliers that are already part of Mindray’s supply chain may be subjected to annual review from a responsible business perspective depending on their performance, risk profile, and importance for the business. The review process monitors, among other factors, the type of supplier, suppliers’ performance in the previous year, and compliance with Mindray’s responsible business requirements, which include prohibition on modern slavery, human trafficking, discrimination, harassment, sexual abuse and child labour.
Supply chain management, monitoring and compliance
We have zero tolerance to slavery and human trafficking. We have a procedure in place to monitor compliance and initiate remediation action. If there is a risk of non-compliance with any of Mindray’s values, which include a prohibition on slavery and human trafficking, we issue a “non-conformity improvement evaluation form” to the supplier. Upon receipt of such form, the supplier has to initiate remediation action. Mindray will then check the effectiveness of the remediation, through a site visit if necessary. If the supplier fails to make effective remediation within the agreed period, Mindray will cease to conduct business with that supplier.
In May 2023, Mindray delivered training on Modern Slavery policies to Supply Chain employees and suppliers.
Training and Further Steps Taken
Communication
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have shared our relevant policies internally with our employees along with this statement.
Mindray (UK) has also recently rolled out a mandatory training for its employees that helps understand how to identify and report signs of Modern Slavery and prevent modern slavery from happening.
Further Steps
In the last 12 months, as part of our commitment to combatting the risk of modern slavery in our operations and supply chain, Mindray has undertaken the following improvement actions:
The “Code of Business Conduct and Ethics” is being updated to better emphasise our commitment to combatting the risk of Modern Slavery and Human Trafficking.
Mindray has also enhanced the “Due Diligence Questionnaire for Business Associates” (e.g.distributors) that, among other things, addresses specifically Modern Slavery and Human Trafficking risks.
Mindray (UK) has rolled out a mandatory training for its employees that helps understand how to identify and report signs of Modern Slavery and prevent modern slavery from happening. The training also:
- Helps understand the scale of Modern Slavery;
- Describes employees’ responsibilities under the Modern Slavery Act 2015;
- Explains what Modern Slavery is;
- Explain how to spot the signs of Modern Slavery;
- and how to report Modern Slavery.
We will continually monitor the effectiveness of any steps taken to ensure that there is no slavery or human trafficking in our supply chains. In addition, Mindray has recognised that there are further opportunities and steps it can take to enhance its commitment to combat slavery and human trafficking and will continue to review and improve on existing practices.
Mindray, as a global medical solutions provider, has recently achieved an outstanding AA rating for its Environmental, Social and Governance (ESG) practices from Morgan Stanley Capital International (MSCI), a renowned international rating agency. This rating is the highest in the A-share market, signifying Mindray's impressive advancement towards being a leader in ESG management across the globe and specifically in the medical device industry.
According to MSCI's latest ESG rating report on Mindray, Mindray’s sustainable development practices in the social and governance areas have promoted the rating upgrade. The company's practices in human resources management, product quality assurance, and business ethics are leading the industry.
Mindray places employees at the center of the sustainable development strategy. Mindray has established 51 overseas subsidiary companies in 42 countries that employ 100% local employees in 29 countries. Mindray prioritizes equality in the workplace, providing equal and broad development opportunities for every individual. Mindray factually respects cultural differences existing between different countries and regions while avoiding discrimination or prejudice based on age, gender, nationality, race, skin color, or religious beliefs.
Regarding its corporate governance and business ethics, MSCI affirms the company's protection of whistleblowers and its regular compliance audits on anti-corruption practices. Mindray advocates and practices complete honesty and trustworthiness in all business operations, strictly complying with any laws and regulations related to anti-corruption, preventing conflicts of interest, anti-fraud, antimonopoly, and anti-unfair competition. The company conducts regular ethics audits and encourages all employees to study relevant system rules and regulations. Furthermore, Mindray invites all stakeholders, including employees, suppliers, and others, to report any illegal or disciplinary action related to the company via various channels - publicly or anonymously. The company firmly protects the rights and interests of whistleblowers and ensures that they are not subjected to any unfair or retaliatory measures.
We believe the above mentioned rating is a recognition for the efforts Mindray is putting to ensure the highest ethical standards are achieved by the organisation, including standards and regulations around Modern Slavery and Human Trafficking risks.
Approvals
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Mindray Group’s modern slavery and human trafficking statement for the financial year ending 31 December 2022. It has been approved by the board of directors of Mindray (UK) Limited with respect to the financial year ending on 31 December 2022 and is signed on behalf of the board by its legal representative.
General Manager
Lei Su