DEBRA Modern Slavery and Human Trafficking Statement

DEBRA is aware of the duty placed on it by the Modern Slavery Act 2015 and is committed to ensure that steps are taken to prevent modern slavery within our organisation.

Our Organisation

DEBRA is a charity registered in England and Wales (1084958) and Scotland (SC039654). It is governed by our Articles of Association and the Objects of the Charity are:

  • to promote research for the benefit of the public into the cause, nature, treatment and cure of Epidermolysis Bullosa and other related medical conditions and to publish the useful results of such research.
  • to relieve physical and mental illness and distress among persons suffering from the said condition by the provision of practical advice, guidance and support for the persons responsible for their welfare and in such other ways as the Trustees shall determine.

Due Diligence, auditing and risk assessment

To help us to identify and mitigate the risk of modern slavery when appointing suppliers we have put a procurement process in place. As part of our due diligence, DEBRA will carry out a risk assessment of our suppliers by including questions in the tendering documents and will take action to eliminate or reduce the risk of modern slavery as appropriate.

Policies and Procedures

We are committed to ensuring there is no modern slavery or human trafficking with the organisation and our Anti-Slavery & Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships. We will implement and enforce effective systems and controls to ensure modern slavery or human trafficking is not taking place within the charity or by our suppliers.

In order to make the procedures to follow clear, we have policies in place alongside this, which include safeguarding, recruitment, procurement, whistle blowing and a code of conduct.


To ensure a high level of understanding of the risks of modern slavery and human trafficking within the organisation and in our supply chains, we will provide training to our staff and will also require any third-party organisations we work with to train their staff.

Effectiveness and continued Improvement

We have a safeguarding committee in place to review our effectiveness in ensuring that slavery and human trafficking is not taking place within our organisation or any of our suppliers and to consider how we can continuously improve. Regular safeguarding audits will also be carried out.


DEBRA Anti-slavery and human trafficking policy

Table of contents

  1. Policy statement
  2. Related documents
  3. Responsibilities
  4. Compliance
  5. Communication & awareness
  6. Breaches of this policy

1. Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. DEBRA has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in the charity or in any of our supply chains.

We are also committed to ensuring there is transparency in the charity and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for DEBRA or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee's contract of employment and we may amend it at any time.

2. Related Documents

  • DEBRA Safeguarding Policy
  • Recruitment Policy
  • Grievance Procedure
  • Procurement Policy
  • Code of Conduct
  • Modern Slavery Statement

3. Responsibility for the policy

The trustee board have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The CEO has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and the Director of People and Director Finance & IT have responsibility for dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the CEO.

4. Compliance with the policy

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. Therefore, due diligence must take place before transactions are carried out with all third-party suppliers and the supplier through their contract must conform to the DEBRA modern slavery policy.

You must notify your manager OR email the confidential safeguarding email address [email protected] as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager OR report it in accordance with our Whistleblowing Policy as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the Director of People or through the confidential safeguarding email.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the charity or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Director of People immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the Resource Centre under policies in the HR folder on SharePoint.

5. Communication and awareness of this policy

Training on this policy, and on the risk the charity faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

Our commitment to addressing the issue of modern slavery in the charity and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

6. Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they beach this policy.