Human Rights & Modern Slavery Policy

Objective

The purpose of this document is to outline Pacific Medical’s commitment to, and support of, the promotion of human rights, and elimination of all forms of modern slavery and human trafficking. This document will guide and inform the decisions, actions and processes conducted by Pacific Medical, its directors, executives, employees, contractors, and suppliers. It will ensure that any actions conducted by these individuals will be in alignment to, and reflective of, our values surrounding these issues.
This document will outline Pacific Medical’s approach to combatting and eliminating modern slavery from within our value chain, and our commitment to respecting human rights in line with the United Nations Guiding Principles on Business and Human Rights (UNGPs).

Our Commitment

Pacific Medical recognises and respects the human rights of every person involved across our operations, supply chain and communities in which we operate. As a major Australian distributor of medical products across various sectors, we understand the significance of integrating human rights considerations into every facet of our business operations. We do not accept any form of human rights abuse and are committed to ensuring that all people are treated fairly, ethically and with respect.
Pacific Medical is committed to the and accordingly this Policy respects all internationally recognised human rights including the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and the International Labour Organisation’s Core Conventions.
While we are committed to and support the promotion of human rights across our operations and supply chain, we also recognise that we are at the beginning of our journey. An important component of this journey is developing, complying with, and communicating this Policy internally.

This Policy will:

Provide a basis and guide for the way in which all Pacific Medical employees, contractors and suppliers must respect human rights and eradicate modern slavery from within operations and supply chain
Ensure our personnel are equipped with the knowledge, resources and support to contribute to the protection of human rights and avoid complicity in adverse human rights abuses; and
Establish minimum requirements for our personnel relating to safe working conditions, non-discrimination, forced labour and freedom of association.

Scope

This Policy applies to, but is not limited to, all Pacific Medical directors, executives, employees, contractors, and suppliers regardless of location or size so far as reasonably practicable. It extends to all Pacific Medical’s operations and procurement activities across our network of warehouses, people and resources.

This Policy always applies and is not restricted by work hours or other time and place considerations. No part of this Policy seeks to exclude any existing policies, commitments, or obligations of Pacific Medical or under Australian law. Where a local regulation or practice conflicts with internationally recognised human rights, Pacific Medical will apply the highest standard possible in the circumstances

Relevant Corporate Policy Principles

The human rights commitments outlined throughout this document are aligned with, and supported by, Pacific Medical’s overarching values, vision and mission, our Supplier Code of Conduct, and any other relevant, internal policy.

Modern Slavery

Pacific Medical welcomes the Australian Modern Slavery Act 2018 (Cth) as an opportunity for the Australian business community to improve governance and accountability, and to use our position and skills to address human rights risk. We will introduce and progress actions that mitigate the impacts of modern slavery on our industry in subsequent reporting periods.
Pacific Medical understands that modern slavery is a persisting issue that is affecting organisations and individuals on a global level. To minimise the risk of modern slavery within our value chain, and to elevate our response to the issue, Pacific Medical has been working with an independent advisory firm to support our organisation with implementing meaningful actions to prevent and mitigate any human rights or modern slavery impacts.

Modern Slavery Actions

In FY23, Pacific Medical has conducted a Supplier Risk Assessment, where higher risk Tier 1 suppliers were identified based off the country, category and dependency risk levels.
We have also conducted a Supplier Due Diligence process, whereby, following the Risk Assessment, we engaged with selected higher risk suppliers to understand their processes, policies and actions with relation to modern slavery and human rights risk.
Corrective Action Plans (CAPs) were developed for each of the higher risk suppliers, based on the responses provided by the supplier and the assessed risk level. The intention of this piece of work was to engage with our key suppliers and communicate our commitments with regard to modern slavery and human rights, understand our suppliers modern slavery and human rights processes, and gain greater oversight over our direct supply chain.
We are also in the process of reviewing our own internal policies and documents to ensure they are reflective of our commitment to modern slavery and human rights. This includes drafting a Supplier Code of Conduct and revising our Supplier Agreements, to sufficiently integrate specific modern slavery and human rights clauses.
Pacific Medical has also developed a 1–3-year modern slavery roadmap, which will highlight the priority actions required to manage modern slavery and human rights risk internally, and to mitigate and minimise across our operations and supply chains.

Internal Remediation Process

Aligned with the UNGPs, Pacific Medical acknowledges its duty to offer or cooperate in remediation to addressing any adverse human rights impacts resulting from its business operations. Pacific Medical takes this responsibility seriously. We have established effective grievance mechanisms for those who are at risk of being adversely affected by our activities.

Pacific Medical follows an informal process, that enables our employees, contractors, agents and others to raise any issues, instances of misconduct or concerns that may arise. Where an incident is to occur, or a concern is to be raised, individuals are aware of the avenues to take to escalate the issue.
The Modern Slavery Working Group is responsible for receiving and reviewing instances of misconduct or concerns that arise. We strongly seek to remediate and mitigate any instances that are flagged and adhere to a stringent process and reasonable steps to remedy the issue.
Governance

The Pacific Medical Modern Slavery working group is responsible for the regular review of this document. Regular review of these processes will occur periodically to ensure that continuous improvement opportunities, actions and commitments are captured in this policy. These reviews can occur on a need basis but no more than two (2) years since this documentation was issued or since the last review occurred.

Communication

This Policy will be publicly available on the Pacific Medical website. It will be internally communicated to all existing Pacific Medical employees, contractors, and suppliers through the appropriate internal channels and platforms. It will also be provided to all new Pacific Medical personnel during the onboarding training process, as well as to prospective suppliers