We abhor the practice of modern slavery. It goes against our purpose which is “the constant pursuit of better” and the values that we uphold every day. We are committed to actively opposing exploitation in all forms and advocating for a place where everyone is treated with dignity, fairness and equality.
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 2024 (also Prima Dental’s financial year).
With over 270 colleagues at our production facilities in the UK; a sales subsidiary in India and joint venture partnerships in Brazil, Hong Kong and China, we produce over 50 million dental burs each year. We supply to more than 90 countries.
We procure a range of materials and services required for both manufacture and business operations. We engage with hundreds of suppliers making our end-to-end supply chains extensive and complex.
A key priority is ensuring the safety and well-being of our colleagues, visitors and business partners throughout our supply chain. We are dedicated to creating a secure and supportive environment where everyone is treated with respect and protected from harm. This focus extends to fostering transparent ethical practices across all levels of our operations.
We promote a high performance and inclusive culture whereby we encourage colleagues to feel comfortable to approach senior managers to raise any issues including mistreatment and/ or exploitation concerns. Senior management liaise with all teams to encourage and listen to feedback to improve practices.
We believe colleagues are well placed to identify and deal with Modern Slavery through the training we have undertaken. We believe this materially mitigates the risk of modern slavery from either going undetected or being inadequately dealt with.
Following a ‘desk-top’ analysis to identify where our risks are, a plan was developed. During 2024 we have achieved the following:
• A supplier risk assessment has been launched across all critical suppliers to Prima Dental UK including a Country based risk assessment which includes geographical
location; vulnerability to modern slavery and the country’s approach to worker welfare provision. Further consideration of industry level exposure to modern slavery will be looked at throughout 2025.
• We have sent a supplier questionnaire to our suppliers to establish a base line for our suppliers Modern Slavery awareness and commitments. This has enabled us to conduct a gap analysis which serves as a collaborative tool with our key partners to foster engagement and drive meaningful discussions.
Throughout this process any supplier classified as medium or high risk will be prioritised for further assessment and remedies developed in partnership with the supplier. We would not hesitate to immediately cease dealings with a supplier if there showed no desire to work with us to improve processes.
After conducting a thorough ethical review of welfare policies for workers across our supply chain, we have measured effectiveness as follows:
• Initial desk top risk assessments have identified weaknesses where focussed efforts will be deployed to encourage our suppliers to engage in continuous improvement of their Modern Slavery strategies. This engagement process seeks to assess our suppliers’ approach to preventing modern slavery in their supply chain.
• We have introduced a KPI aligned with location risk to demonstrate engagement in this process. We have assessed approved direct and indirect suppliers and are working with these businesses to address any areas of weakness. As we develop our own supplier engagement processes, we will review the effectiveness of this as a key metric.
Training and awareness initiatives will remain a core focus in ensuring that all our colleagues understand the importance of the issues relating to preventing Modern Slavery. During 2024 we have carried out the following:
• We have reviewed our training module and are satisfied it remains relevant and fit for purpose. We will review annually. All colleagues have completed the on-line training titled “Business Compliance – Modern Slavery.
• We have developed our intranet to now include learning materials in relation to the identification and prevention of modern slavery.
• On ‘Anti-Slavery Day’ in October 2024 we raised awareness of modern slavery risk via a Social Media campaign.
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. To this end our plan for 2025 is:
• Mitigation of location risk through employee and business partner engagement; awareness; training and policies evidenced through supplier audit and re-approval processes.
• For all suppliers there will be a thorough review of their ethical policies and procedures to ensure continued development and compliance.,
• We are planning to launch our Prima Dental Supplier Code of Conduct to integrate ethical, regulatory and Prima Quality expectations of our Suppliers.
• We will continuously review our supplier quality audits.
• Appropriate in-depth training will be given to the UK Senior Leadership Team.
• Continue to raise awareness to spread the message, via social media, in accordance with internationally recognised Anti-Slavery campaigns.
• Maintain our intranet to educate and share key information about modern slavery.
The Executive Leadership Team of Prima Dental has approved this statement.
Dan Hodgson
Chief Executive Officer
31 January 2025
