Modern Slavery Policy

Aims of this policy

This policy supports our commitment to limiting the risk of modern slavery occurring within our own business or infiltrating our supply chains or any other business relationship.

The policy applies to all persons working for or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, interns and any other third party representative.   

We expect all who have or seek to have a business relationship with the company to familiarise themselves with this policy and to act at all times in a way that is consistent with its values.

We will only do business with organisations who fully comply with this policy or those who are taking verifiable steps towards compliance.

This policy will be used to underpin and inform any statement on slavery and human trafficking that we are required to produce further to the transparency in supply chain requirements of Section 54 of the Modern Slavery Act 2015 (MSA).   

What do we mean by modern slavery?

Modern slavery can take many forms. It is a complex and multi-faceted problem. The MSA covers four key criminal activities:

Slavery: where ownership is exercised over an individual Servitude: involves the obligation to provide service imposed by coercion

Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty.

Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them. 

Other forms of modern slavery, which we will not tolerate, but are not specifically referenced in the MSA include, but are not limited to:

Child labour:  whilst not always illegal in the jurisdiction in which it takes places, child labour involves the employment of children that is exploitative, or is likely to be hazardous to, or interfere with, a child’s education, health (including mental health), physical wellbeing or social development.

All forms of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.

Tackling modern slavery requires us all to play a part and remain vigilant to the risk in all aspect of our business and business relationships.  

How we seek to embed our anti-slavery policy in practice 

To underpin our policy commitments, we have implemented the following measures:

We have conducted risk assessments to determine which parts of our own business and which of our supply chains are most at risk from modern slavery.

Where appropriate, as informed by our risk assessments, we will undertake pre-screening of prospective suppliers in relation to the effectiveness of their existing safeguarding controls and practices in relation to preventing modern slavery occurring within their organisation.

Responsibility for this policy

The Managing Director has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.

The director will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.

All line mangers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day to day performance of their roles.   

Communication and employee awareness training

The director will ensure that relevant staff receive adequate training on this policy and any supporting processes applicable to their role.  

In addition staff receive training on the broader issues of modern slavery so as to assist them in appreciating the extent of the problem of modern slavery and the identify individuals/areas of the business that may be at risk from practices of modern slavery.  

Breaches of this policy

Any breaches of this policy will be taken seriously and dealt with on a case by case basis.

The breach of this policy by an employee, director or officer of the company may lead to disciplinary action being taken in accordance with our disciplinary procedure. Serious breaches may be regarded as gross misconduct and may lead to immediate dismissal further to our disciplinary procedure.

Everybody to who whom this policy applies will be expected to co-operate to the fullest extent possible in any investigation into suspected breaches of this policy or any related processes or procedures.

If any part of this policy is unclear, clarification should be sought from the director.

Status of this policy

This Modern Slavery policy will be reviewed by the Chief Executive Officer on a regular basis.

This policy does not give contractual rights to company employees and we reserve the right to alter any of its terms at any time. We will notify applicable parties in writing of any changes which may affect them.


Modern Slavery and Human Trafficking Statement


This statement sets out Cyden Limited’s (who owns SmoothSkin) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 January 2023 to 31 December 2023.

As a global company, we comply with laws and regulations where we conduct business. We also look to those who provide use with services or goods (collectively “suppliers”) to operate in compliance with all applicable laws, including, but not limited to, supply chain integrity, employment laws pertaining to forced labour and human trafficking, child labour, minimum wages, overtime compensation, hiring, and occupational safety.

Cyden Limited manufactures electronic IPL hair removal devices and skin care devices. We recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Cyden Limited:

Cyden Limited manufactures electronic IPL hair removal devices and skin care devices, which are classed as medical devices and, as such as subject to regulation including ISO:9001 and MDR ISO:13485.  We currently manufacture devices for one single third party organisation and our own brand, SmoothSkin

Countries of operation and supply

We currently operate in the following countries:

  • We manufacture our devices in the United Kingdom and China, with design and development taking place in United Kingdom, China and Japan.  Our devices are available globally and are primarily sold in the United Kingdom, Aisa, United States of America and Australasia.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • Locally quality teams carry out due diligence and audits of our supply chain to check compliance with the Company’s Modern Slavery Policy.
  • Our Business Partners, their suppliers and/or sub-contractors, as well as any other entity directly and/or indirectly belonging or being related, in any way, to the supply chain involved in the manufacturing of our products and/or of their parts, attachments and components, are requested to observe and to protect the rights of the Employees at any time and under any circumstance

High-risk activities

We have identified that our biggest current risks of exposure to modern day slavery sits within the product supply chains of our owned brand regional products. To combat this, we have an established programme of supplier audit and assessment, which is delivered through our own dedicated global sourcing team supplemented, if necessary, by a small number of pre-approved third-party assessment bodies.


Responsibility for our anti-slavery initiatives is as follows:

  • Policies: Any policies required will be agreed and implemented by the People and Culture Manager in conjunction with the Supply Chain Manager.
  • Risk assessments: All of our Business partners and suppliers must agree to provide evidence of their related compliance programs. If our Quality teams identify any non-compliance, we work with our Suppliers on remedial action plans to ensure identified are addressed and corrected. If any supplier is unwilling to work with us to achieve compliance, we will, as a last resort terminate our business relationship. Investigations/due diligence: will be carried out by the Global Sourcing team. Supported by Procurement in the United Kingdom and China.
  • Training: To effectively tackle Modern Slavery and Human Trafficking, we provide awareness training to employees to ensure that they understand their responsibility and steps to take if they witness any occurrence of bad practice.

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can [use our confidential helpline/complete our confidential disclosure form].
  • Modern slavery policy Our policy makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Supplier code of conduct We are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.
  • Recruitment policy We use only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. [Describe the process by which risks of slavery and human trafficking are addressed in relation to agency workers, including examples (not necessarily named) of instances where action has been taken as a result of the risk of slavery and human trafficking.]

Due diligence

We undertake due diligence when considering taking on new suppliers, and regularly reviews existing suppliers. Our due diligence and reviews include:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier;
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits or assessments through the organisation’s own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • creating an annual risk profile for each supplier;
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans;
  • participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular; and
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.


We require staff to complete an online training course.

Our modern slavery training covers:

  • our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within our organisation;
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • what steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.

Board approval

This statement was approved on [date] by our board of directors, who review and update it annually.