SEFAM Medical Ltd - Modern Slavery and Human Trafficking Statement 

 

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 for the financial year ending 2024 and outlines the steps we have taken to combat modern slavery in accordance with the UK Modern Savery act 2015. 

Introduction 

 

SEFAM UK Ltd is committed to preventing all forms of modern slavery and human trafficking in our business operations and supply chains. As a global leader in manufacturing devices for the treatment of sleep apnoea, we recognise our responsibility to act ethically and ensure that all practices within our organisation and supply chains are free from forced labour, human trafficking, and exploitation.  

 

a. Organisation Structure, Business, and Supply Chains 

 

SEFAM Medical Ltd, a subsidiary of SEFAM Group, operates in the United Kingdom and has been active since 2021. Our parent company, SEFAM, was founded in 1982 and is headquartered in Nancy, France. SEFAM is a global manufacturer and supplier of Continuous Positive Airway Pressure (CPAP) and Automatic Positive Airway Pressure (APAP) devices used in the treatment of sleep-disordered breathing. 

SEFAM's products are distributed across more than 60 countries, with its main manufacturing facility located in Nancy, France. Some components, such as electronic parts, are sourced internationally, including from China and France, while final assembly occurs in Nancy. Our supply chain is critical to ensuring the continuous production of innovative, high-quality medical devices, and we maintain strong partnerships with suppliers and manufacturers. 

 

b. Policies on Modern Slavery and Human Trafficking 

 

SEFAM Medical Ltd is committed to operating transparently, ethically, and with integrity. We have a zero-tolerance approach to modern slavery and human trafficking in any form. Our policy on modern slavery and human trafficking is aligned with the principles set out by international human rights standards, including the United Nations Guiding Principles on Business and Human Rights and the International Labour Organisation (ILO) Conventions. 

This policy is integrated into our procurement processes, and all suppliers are required to adhere to SEFAM’s Supplier Code of Conduct, which explicitly prohibits any form of forced or bonded labour, human trafficking, child labour, or other exploitative practices. Our contracts include specific clauses on compliance with modern slavery legislation, and failure to adhere to these standards could result in termination of business relationships. 

 

c. Due Diligence Processes 

To mitigate the risk of modern slavery in our supply chains, SEFAM Medical Ltd has implemented robust due diligence processes. This includes: 

• Conducting risk assessments of our supply chains, particularly focusing on countries and sectors where the risk of modern slavery is higher. 

• Regularly reviewing supplier contracts and requiring evidence of compliance with ethical and legal labour standards. 

• Engaging in open dialogue with suppliers to ensure they meet the standards expected of them. 

• Auditing, where necessary, suppliers that provide critical components, such as electronic parts sourced from China, to ensure compliance with international labour standards. 

These processes are regularly reviewed and updated as part of our commitment to continuous improvement. 

 

d. Risk Assessment and Management 

 

We recognise that parts of our supply chain, particularly in regions where labour laws may not be as stringent or enforced, could be more susceptible to modern slavery risks. We acknowledge the potential risks associated with sourcing electronic components from China, a region that has been flagged for higher risks in labour rights violations. 

 

To mitigate these risks, SEFAM Medical Ltd has: 

 

• Mapped its supply chain to identify high-risk areas and suppliers. 

• Increased scrutiny of suppliers in high-risk regions through enhanced due diligence processes, including requesting detailed information on their labour practices. 

• Worked closely with suppliers to establish clear expectations regarding the prohibition of modern slavery practices and ensured that they share our values on human rights. 

• Strengthened our Supplier Code of Conduct and made compliance with anti-slavery laws a fundamental part of all new and existing supplier agreements. 

 

e. Effectiveness in Combating Modern Slavery 

 

SEFAM Medical Ltd is committed to continuously evaluating the effectiveness of our efforts in combating modern slavery. We measure our progress against several key performance indicators (KPIs), including: 

• Supplier audit outcomes, especially for high-risk suppliers. 

• Feedback from internal and external stakeholders regarding the effectiveness of our due diligence processes. 

• The number of instances where remedial actions were necessary and the outcome of those interventions. 

• The level of compliance with modern slavery and human trafficking policies across our supply chain. 

 

To date, SEFAM Medical Ltd has not identified any instances of modern slavery or human trafficking within our operations or supply chains. However, we are committed to ongoing vigilance and improvement in this area. 

 

 

f. Training and Capacity Building 

 

SEFAM Medical Ltd recognises the importance of ensuring that our staff are well-equipped to identify and address risks related to modern slavery. To this end, we provide training to key personnel involved in procurement, supply chain management, and operations. This training covers: 

• An understanding of modern slavery and human trafficking, including identifying signs of exploitation. 

• The legal framework around modern slavery, particularly the UK Modern Slavery Act 2015. 

• The procedures to follow if there are any concerns related to modern slavery in our supply chain. 

• Best practices for engaging with suppliers on these issues. 

 

We also encourage our employees to report any concerns they may have regarding modern slavery, either through our internal reporting mechanisms or anonymously via a whistleblowing hotline. 

 

Conclusion 

SEFAM UK Ltd is fully committed to maintaining high ethical standards and taking all necessary steps to prevent modern slavery and human trafficking in any form. We will continue to review and enhance our practices to ensure that slavery and exploitation have no place in our business operations or supply chains. This statement will be reviewed annually and updated as necessary to reflect our evolving efforts in this critical area. 

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 for the financial year ending 2024.