Modern Slavery and Human Trafficking Statement

Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015.

It relates to the financial year 1 January 2024 to 31 December 2024. This statement covers the activities of The People’s Dispensary for Sick Animals and its three wholly owned subsidiaries, PDSA Trading Limited, PDSA Property Services Limited, and PDSA PetAid Enterprises Limited.

This statement sets out PDSA’s commitment to identifying, reducing and eliminating slavery and human trafficking within its organisation and its supply chains.

We acknowledge our responsibility to comply with all principles of the Modern Slavery Act 2015.

Structure and Supply Chains

PDSA was founded in 1917 by Maria Dickin with the aim of improving the welfare of pets and alleviating poverty. Throughout the past 100-plus years, we have delivered veterinary support to those in need, as well as providing preventive and educational services.

We have a variety of supply chains that provide goods and services to support the delivery of our frontline services as well as enabling internal functions to deliver services within the organisation. The vast majority of our suppliers and contractors are based in the UK or the EU. We acknowledge that there may be modern slavery occurring in our supply chains that we are not aware of and we are committed to continuously improving our processes and procedures to identify, reduce and eliminate this wherever possible.

Our risk categorisation system is partially based on the Global Slavery Index developed by Walk Free to calculate the level of risk in our supply chain according to country and industry:

High Risk Countries

High Risk Industries

Source: Global Slavery Index | Walk Free

Modern Slavery and Indicators of Forced Labour

We use the definition of forced labour as specified in the International Labour Organization Forced Labour Convention, 1930 (No. 29) as: “all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily”. The eleven indicators represent the most common signs or “clues” that point to the possible existence of a forced labour case:

• Abuse of vulnerability
• Deception
• Restriction of movement
• Isolation
• Physical and sexual violence
• Intimidation and threats
• Retention of identity documents
• Withholding of wages
• Debt bondage
• Abusive working and living conditions
• Excessive overtime

Source: ILO indicators of Forced Labour | International Labour Organization

Policies

PDSA has an Ethical Statement in place that covers a number of wider issues. It is shared with our contractors, and they are required to follow it as part of our contracting process. This was reviewed and updated in 2022.

We have a number of policies that help us to reduce the risks that modern slavery may be part of our own organisation; these include policies covering recruitment, grievances, harassment and bullying, whistleblowing and safeguarding.

Due Diligence Processes

Our Contracts & Procurement Team provide support and guidance to the organisation in relation to procurement activities. As such, our Supplier Questionnaire contains questions relating to the Modern Slavery Act and our New Supplier Request Form requires a statement to be confirmed that due diligence has been carried out in relation to modern slavery. When negotiating contracts, we include clauses relating to modern slavery and PDSA’s Ethical Statement. Any suppliers that our employees identify that may be at risk of having modern slavery or human trafficking in their supply chains are flagged to the Modern Slavery Project Group for review and appropriate action taken.

Modern Slavery Project Group

We recognise that there is always more that we can be doing as an organisation to minimise the risk of modern slavery occurring in our supply chains.

In order to further develop our approach to modern slavery a Project Group has been established by the Executive Leadership Team. This Group is sponsored by the Director of Finance & Resources, led by the Contracts & Procurement Manager and includes representatives from various disciplines including veterinary services, corporate partnerships, digital, data and security, internal audit, and retail & buying.

The Project Group has developed our approach across a number of areas including supply chain risk identification, risk categorisation, auditing methodology, and action plans.

So far the Project Group has:

• Developed and implemented an audit methodology to identify suppliers at risk of modern slavery in their supply chains including:
  • Regular scheduled reviews,
  • Assessment and categorisation of suppliers using a Risk Matrix, and
  • Agreeing appropriate action in line with the level of assigned risk, which may include the use of a Modern Slavery Questionnaire, Remedial Plan and / or action being taken to remove them from our approved supplier list.
• Tracked and logged suppliers in the top 100 by total spend, as well as those in identified high risk areas by country and/or industry.
• Reviewed our key contracts and ensured they contain relevant clauses in relation to modern slavery.
• Liaised with higher risk suppliers to understand their approaches to modern slavery.
• Introduced targeted modern slavery checks in our assessments of potential new suppliers.
• Established a route and process for reporting any suspected modern slavery case.
• Created an internal intranet page to provide our people with information on modern slavery and our related processes.
• Updated our Ethical Statement to capture our stance on modern slavery and human trafficking.
• Built on improving awareness, education and engagement across the organisation.
• Began exploring the possibility of digitalising parts of our modern slavery process to streamline and improve the process.
• Registered our modern slavery statement onto the Government’s voluntary Modern Slavery Statement Registry (modern-slavery-statement-registry.service.gov.uk).

During 2025, we will:

• Continue to build on improving awareness, education and engagement across the organisation.
• Keep up-to-date on Modern Slavery associated legislation and adjust our approach as appropriate.
• Evaluate, improve and update our modern slavery procedure.
• Review all suppliers with an annual spend over £100,000, as well as those in identified high risk areas.
• Agree and implement Key Performance Indicators to measure our performance and effectiveness.

Our Commitment

We recognise the impact that our procurement and purchasing activities, along with our corporate partnerships, can have on reducing modern slavery in the UK and around the world. We are committed to not only challenging ourselves to do better but also our suppliers, contractors and partners.

This Modern Slavery and Human Trafficking Statement was approved by the Trustees at its Council meeting on 27 March 2025.

Page last updated: 31 March 2025