2025 Statement on Compliance with the Modern Slavery Act 2015
This Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes Henry Schein UK Holdings Limited’s (“Henry Schein UK”) slavery and human trafficking statement for the financial year ending December 2024.
This Statement sets out the steps Henry Schein UK takes to understand and address any risk of slavery and human trafficking related to its business.
Organizational Structure
Henry Schein UK, with its headquarters in Gillingham/Kent, is a wholly owned subsidiary of Henry Schein Inc., a FORTUNE 500® company and publicly traded on the S&P 500® and NASDAQ. The Henry Schein group is one of the world’s largest providers of health care products and services to office-based dental and medical practitioners and has a well-developed system of internal monitoring, controls, and policies. Henry Schein UK operates its business under its own name as well as through its subsidiaries.
Henry Schein UK employs approximately 1000 Team Schein Members (TSMs), located in 6 facilities and offers a wide range of medical and dental supplies, equipment, and technical solutions services.
Risks in Our Operations
We recognise that the complex nature of our business and its supply chains means that we need to be vigilant towards any suspected or known instances of modern slavery. Our supply chains include sourcing finished goods from suppliers for resale, as well as sourcing products from manufacturers for sale under a brand owned by Henry Schein, Inc. Henry Schein engages with third party manufacturing factories in Asia which produce Henry Schein branded products including gloves, masks, tissues and various other consumable items, which are sold in the UK. We are aware that these manufacturing factories carry potential risks of forced labour, child labour and human trafficking due to the industry’s high labour intensity and reliance on migrant workers, the relatively low skill levels of workers and low level of regulation in these geographical locations generally.
Our Policies and Due Diligence Processes in Relation to Modern Slavery
The global Henry Schein group, including Henry Schein UK, is dedicated to maintaining high ethical standards. The most fundamental principle of our Worldwide Business Standards (WWBS) – which is our “Business Code of Conduct”— is to “adhere to the legal and regulatory requirements governing all aspects of our business, including the procurement, sale and distribution of our products. This principle applies to our own organization as well as to third parties with whom we work. Our WWBS integrate our responsibilities to society at large, including the commitment to respecting the human rights, dignity, and privacy of the individual as recognized by the principles as defined in the United Nations’ Guiding Principles on Business and Human Rights. We follow applicable labour laws and prohibit child labour, forced labour, or human trafficking by Henry Schein or its suppliers. These expectations are also outlined in our Global Supplier Code of Conduct (“Supplier Code”).
It is our requirement that our suppliers conduct themselves in an ethical and lawful manner, and respect human rights in all their business dealings. We also have continued to use our Distribution and Supply Agreement terms to require our suppliers to confirm that they will comply with all applicable laws in relation to the supply of products under the agreement. When a new supplier is established in our system, a due diligence process is required to be undertaken. This process includes completion by the supplier of a questionnaire, review and approval by the Quality Assurance and Risk Management departments, and an assessment by the Office of Cyber Security. Along with the questionnaire, the supplier also receives a copy of our Global Supplier Code of Conduct and an agreement detailing the supplier’s obligations to comply with all applicable laws in relation to the supply of products to us, both of which need to be signed by an authorized officer of the supplier.
We have a Corporate steering committee for monitoring global requirements for supply chain transparency, which meets regularly to monitor Henry Schein’s compliance with global laws regarding the use of forced and child labour. This group is cross-functional and includes participation from multiple internal teams responsible for compliance, supplier approval, and product sourcing. In consultation with outside counsel and industry experts, we have designated high-risk countries for the use of forced and child labour and monitor suppliers from those countries more closely to ensure their compliance with worker protection requirements. From those countries, 43 suppliers were audited by internal TSMs covering products such as dental instruments, electronics, disinfecting products, and other medical supplies. An additional 23 audits were performed by LRQA, a global market leader in Environmental, Social and Governance (ESG), sustainability and supply chain services, on our behalf.
As a large distributor of gloves to health care facilities, Henry Schein, Inc. participates in the Responsible Glove Alliance, an industry collective that aims to protect workers in Malaysia and reduce the risk of forced labour through the implementation of due diligence and responsible recruitment practices within the supply chain, as well as participating in remediation. Out of the 66 audits of suppliers in high-risk countries we performed in 2024, six were for existing glove suppliers against the SA8000:2014 standard and three were for potential suppliers.
Training
All employees (globally) have access to Henry Schein’s learning management system, which includes learning courses on our WWBS, reinforcing our commitment to respecting human rights and emphasizing the values and responsibilities that we are expected to uphold.
Learning courses related to Modern Slavery provide guidance on how to identify modern slavery and uphold human rights. All TSMs must complete training on our WWBS. Global executives and directors in supply chain related roles (such as procurement) must complete training on human rights in the supply chain. Upon completion of these learning courses, an employee must pass an assessment to demonstrate their understanding and agreement to comply with the requirements.
Monitoring and Evaluation of Suppliers
We monitor key suppliers’ ethical and labour performance through various approaches such as desk audits, site visits, business reviews, supplier scorecards, or other means. We continue to expand our due diligence protocols with advanced standards, tools, and initiatives.
For our Asia-based Henry Schein brand suppliers, we use a social accountability checklist related to child labour, forced labour, health, safety, facilities, working hours, wages, recruitment, etc. as the basis for the social aspects of the audit program. Since 2015, Henry Schein has conducted audits throughout its supply chain with identified actions successfully addressed and closed.
During the reporting period, no instances of modern slavery were reported to us via our Speak-Up Helpline or reporting process or through our risk management processes, including internal audits.
Further Measures
Through a third-party, Henry Schein maintains a worldwide confidential Compliance Helpline which enables Team Schein Members and other stakeholders to raise concerns about potential violations of our Worldwide Business Standards, the Supplier Code, policies, laws, or regulations. Our toll-free confidential Compliance Helpline is available 24 hours a day, 7 days a week, in multiple languages and is accessible via the Corporate Governance Highlights section of our company website. It is regularly communicated to TSMs through learning modules, managerial toolkits, communications, our intranet sites, and posters in each of our facilities. Reports may be made anonymously but we request that anonymous reports provide sufficient detail and documents so that the matter can be investigated. Additionally, Henry Schein has a policy against retaliation for speaking up in good faith.
We continually review the language in our HR policies to reinforce our zero-tolerance message on forced and child labor and are committed to continuously assessing our supply chains.
Approval
This statement on Modern Slavery and Human Trafficking is approved by the Board of Directors of Henry Schein UK.
Signed for and on behalf of the Henry Schein UK:
Vikki Goodall, Managing Director