This statement explains the steps that we have taken to eliminate slavery and human trafficking from our supply chain. This disclosure is intended to provide our customers with information that will allow them to make more informed decisions about the goods they are purchasing.
Company Structure and Business
LimaCorporate aspires to be the leading company in niche orthopaedic markets to improve surgeon and patient experience, offering innovative, tailored solutions. Our over 800 employees in 24 countries are united in a common mission: to offer innovative solutions to assist orthopaedic surgeons in restoring the Emotion of Motion. More information on our company structure can be found on our website by clicking here.
Our Supply Chains
LimaCorporate takes an end-to-end view of our supply chain. This starts with a close collaboration between our research & development and commercial colleagues to safely and efficiently plan, source, make, and deliver a high-quality and reliable supply of all of the products in the LimaCorporate portfolio.
We purchase goods and services from a small number of suppliers from around the world, the majority of whom are located in Europe, USA and New Zealand. Our supply chains include:
- Suppliers for raw material (e.g. titanium, steel, polyethylene...)
- Suppliers for semi finished implants parts (e.g. casting and forgied parts)
- Suppliers for instruments
- Suppliers for services (e.g. transport)
The success of our business depends on our ability to collaborate with suppliers that not only provide the highest quality products and services, but are philosophically and strategically aligned with our commitment to our social and environmental responsibilities.
LimaCorporate is committed to ensuring that it conducts its business worldwide in compliance with all applicable laws and fair labour practices, as evidenced by our Code of Ethics, and our own Corporate Compliance Policies, which can be viewed on our website by clicking here.
Supplier Adherence to our Values and Ethics
Managing the human rights considerations in our supply base is a critical and complex undertaking. We have a dedicated compliance team, which consists of involvement from the following departments:
- Human resources
- Legal and compliance
LimaCorporate takes the following steps to manage our supply chain relationships responsibly:
- Verification/Due Diligence: LimaCorporate has a zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our Code of Ethics we have in place a supply chain assessment programme. We evaluate prospective suppliers based on risk prioritization during supplier selection. Prioritisation is mainly based on the supplier category, geographical location, use of sub-contracting, make-up of workforce, and financial value of the transaction. Each factor is assigned a high, medium, low rating, and an overall risk score of the supplier is made. Any high-risk factors are immediately followed up on with that supplier. Thereafter, we periodically review the supplier risk factors depending on their role in our supply chain.
- Audit: LimaCorporate currently conducts audits of select suppliers who impact our quality and financial systems based on internal risk assessments. However, these audits are not designed to explicitly confirm compliance with company standards in the areas of slavery and human trafficking.
- Certification: Our standard contracts with suppliers require compliance with all applicable laws. Our General Purchase Terms and Conditions require that suppliers recognise the requirements of our Code of Ethics and accepts them in full, and gives an undertaking that they will not conduct themselves in contrast with our Code of Ethics.
Our Code of Ethics and our Corporate Compliance Policies describe our commitment to sustain an ethical supply chain. In particular, our ‘Model for Organisation, Management and Control’ (pursuant to Italian Legislative Decree No. 231) also governs our internal accountability processes, and is available on our website here. Violation of Company policies and procedures is reportable through specific internal channels. All such reports of allegations of violations will be promptly investigated and, if the result of the investigation indicates that corrective action is required, the Company will decide what steps to take to rectify any problem and/or avoid the likelihood of its recurrence. A specific e-mail address is available to anyone to report a concern about the business conduct of our employees or suppliers, or to ask questions about our business conduct policies.
Compliance training is required of all employees, and compliance with communication, training and execution of our Code of Ethics is audited. We will make this training mandatory for new hires and existing employees in the supply chain management area.
Our actions as described above support the LimaCorporate long-term commitment to respect the human rights of all people and to improve the quality of life in the communities we serve.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st of December 2017.
Chief Executive Officer LimaCorporate S.p.A.
Last updated: July 2018