Modern Slavery Statement | Orthotix

Slavery & Human Trafficking

This statement is made on behalf of Dacey Ltd (T/a Daceys & T/a Orthotix) outlining the steps we have taken to combat slavery and human trafficking.

Organisational Structure

Dacey Ltd is a Welsh Company, based in Cardiff, established in 1972, providing all types of bespoke and stock orthotic products and comprehensive Orthotic Services to NHS partners across South and Mid Wales, the West Midlands, Southwest England, London and Ireland.

Dacey Ltd is fully certified to ISO 13485, ISO 14001, ISO 27001, ISO 45001 and registered with the MHRA complying with all relevant clauses within the EC Directive 93/42/EEC for UKCA & CE marking purposes. During our financial year ending 31st October 2025, the average number of employees working for Dacey Ltd was 95.

Our Business

A full range of bespoke orthotic products are manufactured onsite in our main facility in Cardiff. These include bespoke surgical, modular and stock footwear, functional foot orthoses, plastic, metal and leather orthoses and fabric support garments.

We also provide a full range of ready-made ’Off the Shelf’ orthotic product which are stored and distributed from our Cardiff warehouse facility.

Areas of Our Business Most at Risk

We recognise that the parts of our business most exposed to modern slavery and human trafficking risks are those involving external supply chains, manufacturing partners and labour-intensive activities. This includes the sourcing of materials, components and finished orthotic products; outsourced or third-party manufacturing; warehousing, storage and distribution activities; and any use of temporary, agency or subcontracted labour. We consider these areas to carry increased risk where there is reduced visibility beyond our direct suppliers, where products or materials are sourced through extended supply chains, or where workers may be more vulnerable due to the nature or location of the work. These risks are managed through supplier engagement, due diligence checks, contractual expectations, site visits where possible, and the reporting and escalation processes described in this statement.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our Anti-slavery statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Our own recruitment processes are transparent, and we communicate directly with candidates to confirm job arrangements. We do not charge recruitment fees to workers or job applicants, and we expect the same standard from recruitment agencies, labour providers and suppliers. Where recruitment or placement costs are incurred, these must be borne by the employer or relevant supplier and must not be recovered from workers through deductions, deposits, inflated accommodation or transport charges, or any other mechanism. New employees are vetted; we ensure that identities are confirmed, right-to-work checks are completed, and wages are paid directly into an appropriate personal UK bank account. We also have a policy in place to protect public-interest whistleblowing by our staff.

We prohibit forced, bonded or involuntary labour in our business and supply chain. Overtime must be voluntary, must not be used as a form of coercion or discipline, and must comply with applicable working time, rest break and wage requirements. Workers must be free to leave employment subject only to lawful and reasonable notice provisions.

We prohibit the use of child labour and require all workers in our own operations and supply chain to meet the minimum legal working age applicable in the country of work, and in all cases to be protected from hazardous, harmful or exploitative work. Suppliers are expected to maintain suitable age-verification controls and to notify us immediately of any suspected breach so that appropriate safeguarding, remediation and escalation action can be taken.

We prohibit the confiscation, withholding or unreasonable restriction of workers’ identity documents, passports, visas, work permits, bank cards or other personal documents. Where copies are required for lawful verification or audit purposes, they must be handled securely, and workers must always retain possession and control of their original documents.

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and migrate risk –

We build long standing relationships with core suppliers and manufacturing partners which are serviced with agreements stipulating our approved codes of practice.
We require suppliers, labour providers and recruitment agencies to confirm that workers are not charged recruitment fees, that overtime is voluntary, that child labour is prohibited, and that workers retain control of their own identity documents.
We conduct and record regular supplier site visits where possible and obtain suppliers’ own supply chain slavery and human trafficking statements.
We make clear to all suppliers our expectations of business behaviour.
We have in place systems to encourage the reporting of concerns, including concerns about recruitment fees, compulsory overtime, child labour, or retention of worker documents.
We are committed to continually improve our processes and controls.

Supplier Adherence to Our Values

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with our values and to cascade equivalent standards to their own suppliers and labour providers. This includes prohibiting worker-paid recruitment fees, compulsory overtime, child labour and the confiscation or withholding of worker documents. We will assess any instances of non-compliance on a case-by-case basis, and take appropriate action where it is found, including corrective action plans, increased monitoring, suspension of supply or the termination of contracts.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chain and our business, we provide training to relevant members of staff. All Directors and Senior Managers have been briefed on the subject.

Our Effectiveness in Combating Slavery and Human Trafficking

We use the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

Completion of audits including site visits where possible.
Use of labour monitoring and payroll systems.
Supplier confirmations or contractual controls covering no worker-paid recruitment fees, voluntary overtime, prohibition of child labour and workers retaining control of their own documents.
Level of communication and personal contact with supply chain to ensure their understanding of, and compliance with, our expectations.
Supplier/Manufacturing agreements put in place stipulating our approved codes of practice.

Our actions taken to combating slavery and human trafficking and ongoing commitment

We have carried out regular assessments and supplier site visits on our core and non-core suppliers. We understand that we have a responsibility to continue to assess and mitigate the risk of modern slavery throughout our business and supply chains. As part of our work for the next financial year, we will monitor the effectiveness of the actions we have already taken over the past 12 months.

Dacey Ltd remains committed to doing everything it reasonably can to contribute toward helping eradicate modern slavery and human trafficking.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31st October 2024/25.

Signed by:

Name: Paul Cooper

Position: Chief Executive Officer

July 2026 - This policy statement will be reviewed annually and published.