Human rights due diligence
Initially risks were identified at UG Healthcare Corporation factories through third party assessments as well as site inspections carried out by a customer in 2016. A process to remedy most of these risks was undertaken;
- Document retention; albeit for security of the document and written, documented consent of the holder was obtained
- Overtime; where Malaysian law is at odds with international best practice
- A number of low level health and safety findings which were remediated
A follow up report by the same customer in 2019 identified the following risks;
- Document retention; remediated by the provision of secure lockers available at both the factory and dormitories
- Recruitment fees charged by recruitment agents in migrant workers’ home countries; remediated during 2021
- Overtime; in line with Malaysia national law
- A number of low level health and safety findings in the factories; remediated
- A number of low level health and safety findings in dormitories; remediated and provided in the language spoken in each dormitories
This led to us to begin our own journey into social and ethical issues, resulting in our application to join ETI in early 2020.
As the need for engagement deepened, in 2022 we began working with Impactt Limited, a leading employee-owned consultancy that specialises in ethical trade and human rights, whose investigations provide a more comprehensive overview of any issues on a given site. The results of these assessments led UGHC to fundamentally overhaul their recruitment process, introduce the WhistleB whistle blowing system and clarify a range of documents processes and in all relevant languages,
Subsequent assessments have shown that we are at low risk in all 11 of the ILO’s indicators of forced labour.
We understand the issues in rubber products manufacturing is essentially universal in Malaysia and our other suppliers in this country have, or have had, the same issues. As they are competitors as well suppliers, it makes for a challenging relationship with these matters. In addition to those audits undertaken at the group’s factories, we have also undertaken similar assessments on our primary vinyl glove supplier and one of our larger contingency nitrile suppliers and they have also indicated that they are low risk in all 11 of the ILO’s indicators of forced labour.