Actions Medline takes to assess and address modern slavery risks
Medline’s policy framework
Medline is committed to legal, ethical and socially responsible business and employment practices and treating workers with dignity and respect throughout its global operations and supply chain. Group-wide policies and procedures relevant to preventing slavery, forced and child labor and human trafficking include Medline’s SCOC, ECOC, Non-retaliation policy and Ethical Sourcing Guidelines.
Medline bases its policies on key international human rights principles as set out in agreements including core ILO conventions and the UDHR. Medline seeks to comply with local labor and related laws and regulations at national and sub-national levels in the countries where it operates and requires its suppliers to do the same.
Addressing modern slavery risk in Medline’s operations
Medline’s recruitment and employment policies and ECOC are enforced by local human resources representatives at all Medline-owned factories, distribution centers and sales offices around the world. Medline’s aim is to avoid slavery, forced labor, child labor, or human trafficking in its business operations and direct workforce. Medline implements strict employment practices and procedures across its global business that adhere to local labor laws.
Medline’s operations must comply with all applicable environmental laws and regulatory requirements, abide by strict health and safety measures, and follow principles as set forth in relevant Medline policies. All employees are required to act in accordance with standards set out in the ECOC in the course of their work.
Medline has grievance mechanisms in place to allow Medline personnel to raise concerns about working conditions or violations of law.
Addressing modern slavery risks in Medline’s supply chain
In 2020, Medline undertook an in-depth review process to enhance its ethical sourcing policies and procedures by benchmarking against the UNGPs and international best practices that led to the formation of Medline’s Ethical Sourcing Program (ESP).
Medline’s ESP consolidates and builds on efforts to promote respect for human rights in its global operations and supply chain and is based on eleven pillars:
- Roles and responsibilities, including oversight to Medline’s Ethical Sourcing Committee (ESC)
- Ethical Sourcing Standards (ESS)
- Risk assessment
- Supplier engagement
- Social compliance audits
- Grievance mechanisms
- Customer engagement
- Training and capacity building
- External reporting and communication
- Assessing effectiveness
Governance and oversight
The commitment of senior leadership is essential to advance the key priorities of the ESP. Medline’s senior leadership, including Charles Mills, CEO, Andy Mills, President and James Abrams, COO, consider ethical sourcing to be Medline’s moral and legal obligation and expect employees to do so also. Medline created an ESC to lead Medline’s ESP that includes representatives from Legal, Ethics and Compliance, Corporate Social Responsibility and Technical Affairs (including Sourcing) functions.
Medline takes a risk-based approach to ethical sourcing to focus efforts where the risks are greatest and where Medline can assert leverage to achieve positive change. As noted above, this involves additional scrutiny of suppliers associated with relatively higher modern slavery risk. Medline engages third-party consultants to conduct periodic comprehensive assessments and verify first tier suppliers to assess their risk profiles. Depending on the risks identified through such assessments, Medline may implement a variety of risk mitigation measures, such as obtaining documentation from suppliers, ongoing monitoring, or audits. Medline also engages in risk assessment and mitigation for suppliers below the first tier of its supply chain when risks come to its attention through due diligence efforts or other sources.
Medline performs risk assessments of all new suppliers. Depending on the results of the risk assessment, Medline may require an audit, additional diligence or corrective actions, or decline to enter into a business relationship with the supplier.
Medline’s SCOC applies the prohibition of forced labor, child labor and other practices inconsistent with international human rights standards to every first-tier supplier that provides us with raw material, component parts, or finished Medline-branded product and requires first-tier suppliers to conduct appropriate due diligence to evaluate whether their suppliers, subcontractors and labor brokers apply standards consistent with Medline’s ESS.
Medline requires suppliers to meet minimum standards in relation to, among other things, compliance with applicable laws, wages and benefits, worker health and safety, and working hours. All suppliers must agree to adhere to the SCOC as a condition of their relationship with Medline and apply its standards to their own suppliers. Where necessary, Medline works with suppliers to enhance their performance against the standards set forth in its SCOC.
Social compliance audits
Medline continuously evaluates risk using an assessment, audit and evaluation process built on internationally recognized human rights standards, conventions and principles.
Medline uses audits as both a risk assessment tool for new suppliers and a monitoring tool for existing suppliers.If a potential supplier is classified as high-risk during the risk assessment process, Medline will conduct an audit of the supplier to better understand its risk profile and what remedial steps may be needed to proceed with the relationship.
Medline also conducts audits of existing suppliers to assess compliance with its SCOC and ESS. Audits may be routine and related to a supplier’s risk profile or conducted in response to a grievance or incident. Audits may be performed by Medline personnel or third party auditors and they may be announced or unannounced. All audits are conducted in line with best practices concerning social auditing, including SA8000® principles. Audits must be conducted by trained, qualified auditors. Between 2015 and 2020, Medline’s internal auditors conducted 546 social compliance audits globally including 85 in 2020.
One of the challenges Medline faced while conducting and assessing the results of social compliance audits was mitigating modern slavery risks among groups of migrant workers. Medline’s social compliance audits seek to identify these risks through a combination of hands-on investigations of supplier records and conversations with the workers themselves.
Where issues of concern are identified, Medline works with suppliers to develop remediation plans. Where possible, Medline uses its leverage to work with suppliers to improve their performance and conditions for workers. However, where suppliers are unwilling or unable to meet Medline’s standards within a reasonable timeframe, Medline will ultimately disengage from the supplier relationship.
Medline has put in place grievance mechanisms that allow both Medline personnel and workers in suppliers’ facilities to raise concerns about potential violations of law or Medline’s ESS. Information on grievance mechanisms is posted in appropriate local languages in its facilities and all employees are encouraged to report concerns about potential labor or human rights abuses. Medline encourages its suppliers to put in place effective grievance mechanisms of their own. However, if workers feel that they cannot present a grievance to their direct employer, they are encouraged to reach out to Medline directly.
Medline seeks to respond to actual or potential risks of slavery, forced or child labor, or human trafficking in accordance with best practices—including through supplier engagement, enhanced due diligence, training and capacity building, further social auditing, and implementing corrective and preventive action plans. In line with the UNGPs, Medline seeks to leverage its influence to improve suppliers’ performance. However, where necessary Medline may terminate its business relationship with non-compliant suppliers.
A fundamental component of Medline’s approach to ethical sourcing is training and equipping its employees to identify and respond to risks in its global supply chain. All employees are familiarized with the ESP in new hire training and thereafter, on an annual basis. This training informs employees about Medline’s commitment to social compliance and provides them with a basic understanding of the ESP. Employees in key functions, such as quality assurance and social compliance auditing, receive focused training on topics that include slavery, forced labor and human trafficking.