Modern Slavery Statement

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1^st July 2024 to 30^th June 2025.

The statement sets down Safeguard Medical’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Employees are expected to report their concerns and management to act upon them.

Organizational structure and supply chains

This statement covers the business activities of Safeguard Medical Holdco Limited which are as follows:

• Manufacturer, sales and distribution of medical devices, operating in United Kingdom, Norway, Sweden and Israel.
• Responsibility for the Company’s anti-slavery initiatives is as follows:

1. Policies: The Director of Human Resources and the Director of Distribution and Supply chain are responsible for creating and reviewing anti-slavery policies. The process by which policies are developed is looking at best practice and adapting to the needs of the Company.
2. Risk assessments: The Health & Safety Representative is responsible for risk assessments in respect of human rights and modern by a process of looking at best practice and adapting to the needs of the Company.
3. Due diligence: The Director of Human Resources and the Director of Distribution and Supply chain is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all HR and Supply Chain employees to complete annual online Modern Slavery Training eLearning. The training provides the knowledge on how to report, acknowledge and how to handle modern slavery in and around the workplace.

Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

2. Whistleblowing policy – the Company encourages all its workers, customers, and other business partners to report any concerns related to its direct activities or its supply chains.
3. Code of Conduct – The Code of Conduct sets down the actions and behavior expected of employees when representing the Company.

 

Due Diligence Processes for Slavery and Human Trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners and/or evaluating the modern slavery and human trafficking risks of each new supplier and/or invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Performance indicators

The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains:

1. Requiring all relevant employees to have completed training on modern slavery annually.
2. This Modern Slavery and Human Trafficking Statement will be reviewed quarterly and updated as necessary.
3. The Executive Leadership Team endorses this statement and is fully committed to its implementation.
4. This Modern Slavery and Human Trafficking Statement has been approved and authorized by the Company’s Global SVP of HR and Senior Director of Global Distribution and Supply chain.