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Modern Slavery Statement

Introduction

Hidden Hearing is committed to being a responsible employer and will seek the same from its suppliers.

Organisational structure and supply chains 

Hidden Hearing is a private hearing aid specialist with more than 50 years’ experience and over 300 locations nationwide.  The Head Office is in Maidstone, Kent and the organisation is owned by Demant A/S, a quoted, Danish, vertically integrated hearing healthcare group.

In 2010, Demant joined the United Nations Global Compact.  The Group reports annually on its actions and initiatives based on the 10 UNGC principles in the four areas of human rights, labour rights, environmental and anti-corruption actions. The Group believes this helps to scope its commitment to corporate responsibility and align strategies and goals.

As a global business that engages suppliers all over the world, Demant is attentive to how it deals and interacts with its suppliers. Demant requires that its direct suppliers sign and comply with the Demant Group Third Party Compliance Code.  Currently 322 out of 327 active direct Demant suppliers for the Hearing Aid side of the business have now signed up to the code.

The code is part of the Business Ethics Compliance programme. It lists criteria governing aspects of human and labour rights, including slavery prevention, health and safety measures, environmental issues, as well as anti-corruption. It helps our suppliers adhere to social and environmental standards and contributing towards the protection of human rights.

In 2020, Demant published a Code of Conduct for all employees in which its commitment to internationally recognised human rights standards, relevant laws and regulations aimed at protecting and promoting human rights globally and at work.  Demant is committed to striving to meet local human rights standards in the countries where it operates.

To support the Code of Conduct, Demant introduced a global whistleblower hotline.  This enables employees to report genuine concerns related to the direct activities, or the supply chains of our business, including any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The system guarantees confidentiality and anonymity.  All data provided is subject to data privacy regulations. Demant will ensure that there will be no discriminatory or retaliatory actions against employees who file a complaint with or raise concern to the company in good faith.

Demant sets the following expectations for its employees:

  • Do your utmost to never discriminate based on gender, ethnic origin, race, religion, age or sexual orientation.
  • Adhere to laws and regulations relating to labour conditions, ensure that employees and other workers are compensated fairly and ensure a good working environment.
  • Participate in the development of a culture that supports and respects human rights.

Hidden Hearing has approximately 530 employees in four main categories, Hearing Aid Dispensers, Branch Coordinators, Support and Management.  We use some temporary agency staff whom we book through an approved list of recruitment agencies. The majority of products we sell are manufactured by Demant in Poland. We purchase other goods and services from a range of providers, the four largest in terms of budget spend being shop rentals, cars, IT and marketing services.  

All our Hearing Aid Dispensers are registered with the Health and Care Professions Council which has a professional code of conduct.

We pay above the National Minimum Wage for all employees.

Countries of operation and supply

We operate in England, Wales and Scotland. 

Responsibility

The Board of Directors of Hidden Hearing is responsible for the development and review of policies.

The responsibility for risk assessment in the context of human rights and modern slavery has been delegated by the Board to the Head of Human Resources. 

Responsibility for investigations/due diligence:

  • Head of Human Resources: Employment and use of agency staff
  • Health and Safety Manager: Estate contractors and sub-contractors
  • Finance Director: Suppliers
  • Group Legal: Whistleblowing reports

Relevant policy, procedures and values

Whistleblowing policy: In 2020, Demant reviewed its Whistleblowing policy which was adopted by Hidden Hearing.

Best Practice Recruitment Guidelines: We have a thorough 11-step recruitment process driven by HR to ensure that our recruitment practices meet and where possible exceed our legal responsibilities.  We provide training to all employees involved in the recruitment process.

Temporary Staff: We use an approved list of reputable employment agencies and verify the practices of any new agency added to that list.  We currently use Adecco agencies for temporary staff; they have a zero-tolerance approach to modern slavery and human trafficking within their business and supply chains. They published their first statement last year and since then have continued to increase their work in this area.

Employee code of conduct: The Demant Code of Conduct is the framework that sets the minimum standards and ethical principles applicable to all employees regardless of location and nature of work.  The Code of Conduct provides everyone with a common understanding of how we conduct business. We adhere to the laws of each countries in which we operate and conduct business in line with the UN Global Compact principles and relevant internationally recognised standards. We adhere to quality regulations and conduct responsible marketing.

Employee code of conduct: The handbook makes clear the actions and behaviours expected of our employees at work and representing the company. We strive to maintain the highest standards of employee conduct, engagement and ethical behaviour across the business.

Monitor and Review

We assess risk using the Slavery and Trafficking (SaT) Risk Assessment template.  The most recent assessment was carried out by the Head of Human Resources and the Finance Director in March 2021.  We will review, at least annually, how we operate in the light of this assessment to ensure the embedding of respect for human rights and zero tolerance of modern slavery.

Training

All Hidden Hearing employees will receive training on the Demant Code of Conduct in 2021.

Measures of Success

All employees to have a sound understanding of the Code of Conduct and pass the training modules.  The training will ensure that employees know how to raise issues and have the confidence to do so.  Refresher training will be offered every 2 years.

Board Approval

This statement was approved on 25th March 2021 by the organisation's board of directors, who will review and update it annually.

Director's signature:

Graham Lane Hidden Hearing signature

Director's name:  Graham Lane, Managing Director

Date: 25-03-2021