Modern Slavery Statement

RAYNER GROUP MODERN SLAVERY ACT 2015 STATEMENT

INTRODUCTION

Rayner Surgical Group Limited is the parent company of the Rayner group of companies (‘Rayner’). Rayner is a British manufacturer and global supplier of medical devices and pharmaceuticals in the ophthalmology sector. The business engages over 800 employees worldwide and operates in numerous countries across the globe.
Rayner is headquartered in Worthing (UK) which hosts our central functions including manufacturing, marketing, IT, quality assurance, regulatory affairs, supply chain, HR, finance and legal departments. We have direct subsidiaries in Australia, Austria, Brazil, Canada, France, Germany, India, Italy, Poland, Portugal, Spain, Switzerland and USA which operate our business at a local level.

OUR SUPPLY CHAINS

As a business that develops, manufactures and sells medical devices and pharmaceuticals, we procure a wide range of goods and services to support the delivery of our business strategy. We consider the highest potential risk areas in relation to modern slavery are in our supply chain.
To mitigate the risks that could be associated with our business and our supply chain, Rayner has put in place policies, procedures and processes to detect and avoid incidences of modern slavery and human trafficking.

RAYNER POLICY AND SUPPLIER ADHERENCE TO OUR VALUES

The Rayner Group Labour Standards Policy reflects our commitment to acting ethically and with integrity in all our business relationships. To achieve this, we seek to implement and enforce effective systems and controls, designed to ensure slavery and human trafficking is not taking place either in our business or within our wider supply chain.
We expect our suppliers to share this commitment to labour standards, human rights and ethical conduct; accordingly, we require that they conduct their employment practices in full compliance with all applicable laws and regulations.

In August 2023, the Rayner Group established an ESG Committee to formally oversee Rayner’s ESG activities, including the steps taken to address modern slavery risks relevant to our business. The ESG Committee includes C-Suite and senior leaders from across the business including the Chief Operations Officer, General Counsel, VP Human Resources, VP Commercial (Europe) and the VP Business Development. The ESG Committee plays an active role in ensuring relevant ESG strategies, policies and processes are in place, providing guidance, oversight, and strategic recommendations to the leadership team of the Rayner Group.

DUE DILIGENCE PROCESSES FOR COMBATING SLAVERY AND HUMAN TRAFFICKING

Rayner has a formal supplier approval process to support the business in minimising risk when procuring goods and services. This is supported by Quality Assurance Audits which specifically address modern slavery and human trafficking. Wherever possible, for our critical and higher risk suppliers, we ask them to sign up to the Rayner Group Supplier Code of Conduct, which includes commitments to minimum acceptable standards of conduct across human rights, labour, environment, anti-corruption, integrity and business ethics, which must be adhered to in addition to compliance with all relevant national and international laws and legislation.

Should we believe that a supplier is not undertaking adequate action to prevent modern slavery or human trafficking, or is acting in breach of Rayner’s policies, the relationship with the supplier would be investigated and, if deemed appropriate, terminated.

We also provide a confidential whistleblowing hotline which allows our employees and third parties to report any suspicions of slavery within our operations. Any such reports are promptly investigated and we are committed to effectively addressing any issues found, which may include termination of the supply relationship.

RISK ASSESSMENT, TRAINING AND KEY PERFORMANCE INDICATORS

In line with our core value of continuous improvement, Rayner is looking to enhance its labour standards processes and procedures through:

  • Improved identification and assessment of potential risk areas in our supply chains;
  • Monitoring of potential risk areas in our supply chains and improved follow-up procedures;
  • Provision of effective, tailored training to our procurement and supplier-facing staff on modern slavery risks / labour standards;
  • Effective investigation and elimination of wrong-doing within our organisation and effective communication and enforcement of our policy and standards amongst our suppliers and others with whom we do business;
  • Pro-active engagement with industry standards including the NHS Labour Standards Assurance Scheme and the UK Government Modern Slavery Assessment Tool;
  • Participation in environmental, social and governance initiatives facilitated by our private equity investors, leveraging those relationships and accessing insights to current best practice and procedures in the field of labour standards.
  • External benchmarking on an annual basis covering environmental, social and governance matters, to chart our progress and encourage improvements.

Our current KPIs are based on material concerns or reported breaches of the Rayner Group Labour Standards Policy. There were no material concerns or reported breaches of the Rayner Group Labour Standards Policy for the financial year ending 31st December 2023.

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 (the ‘Act’) and constitutes the Modern Slavery and Human Trafficking Statement for the Rayner Group for the financial year ending 31st December 2023. It was signed on behalf of the Board by:

Tim Clover

Chief Executive Officer

Rayner Surgical Group Limited

Date: 28th March 2024