Modern Slavery Policy

 

Modern Slavery and Human Trafficking Statement

For the Financial Year Ending 31 March 2026

1. Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by TRB Chemedica (UK) Ltd during the above financial year to prevent modern slavery and human trafficking within its own business operations and supply chains.

TRB Chemedica (UK) Ltd is committed to conducting business ethically, with integrity and transparency. We operate a zero-tolerance approach to modern slavery, forced labour, bonded labour, child labour and human trafficking and expect the same high standards from all organisations with which we do business.

2. Our Organisation

TRB Chemedica (UK) Ltd operates within the medical device sector and its principal business activity is the supply and distribution of medical devices within the United Kingdom.

Our supply chain includes manufacturers, distributors, logistics providers and other suppliers supporting our business operations. We recognise that, although our direct operations present a relatively low risk of modern slavery, risks may exist within wider supply chains and we are committed to identifying and addressing those risks.

3. Our Policies

Our commitment to ethical employment practices is supported by our Labour Standards Assurance System (LSAS), first published on 4 September 2019. The policy applies to both our own organisation and our supply chain and is reviewed annually as part of the Company's Management Review process.

Adequate financial and management resources are made available to support implementation of the Labour Standards Assurance System.

The policy is communicated to all employees during their employment and made available to key suppliers, who are expected to communicate equivalent standards throughout their own supply chains where appropriate. The policy is also published on the Company's website.

In addition, suppliers are expected to comply with:

  • All applicable national employment and labour legislation.
  • The principles contained within the Labour Standards Assurance System (LSAS).
  • The Ethical Trading Initiative (ETI) Base Code.

4. Due Diligence

TRB Chemedica (UK) Ltd seeks to ensure that suppliers operate in accordance with applicable labour legislation and recognised ethical standards.

Our due diligence activities include:

  • Communicating our Labour Standards Policy to key suppliers.
  • Requiring suppliers to comply with applicable legislation and recognised ethical labour standards.
  • Expecting suppliers to maintain equivalent standards within their own supply chains.
  • Reviewing supplier relationships where concerns regarding ethical practices are identified.
  • Taking appropriate action where evidence of non-compliance is identified, which may include requesting corrective actions or reviewing the ongoing business relationship.

The Company will continue to develop and strengthen its supplier due diligence processes as part of its commitment to continual improvement.

5. Risk Assessment and Risk Management

The Company recognises that modern slavery risks can exist within global supply chains.

Our assessment considers factors including:

  • The nature of goods and services procured.
  • Geographic location of suppliers.
  • Supplier performance and reputation.
  • Any reported concerns regarding labour practices.

Where higher-risk suppliers or activities are identified, additional enquiries or monitoring may be undertaken to ensure compliance with our ethical standards.

6. Minimum Labour Standards

The Company has established the following minimum labour standards, which apply throughout its operations and form the basis of supplier expectations.

Child Labour

The Company does not employ or support the use of child labour.
Where young workers are employed, suitable risk assessments will be undertaken to ensure they are not exposed to hazardous work and that working hours comply with applicable legislation.

Forced and Compulsory Labour

The Company does not engage in or support forced labour, compulsory labour, bonded labour, debt bondage or involuntary prison labour.

Employment is freely chosen and employees are free to leave their employment upon giving reasonable notice in accordance with their contract of employment.

Health and Safety

The Company is committed to providing a safe and healthy working environment.

Appropriate measures are taken to minimise workplace risks, provide suitable training, maintain safe working practices and ensure employees have access to clean welfare facilities and drinking water.

Overall responsibility for Health and Safety rests with the Managing Director.

Freedom of Association

The Company respects employees' rights to freedom of association and collective bargaining in accordance with applicable UK employment legislation.

Equality and Non-Discrimination

The Company does not tolerate discrimination in recruitment, remuneration, promotion, training, termination or retirement on the grounds of race, nationality, ethnic origin, religion, sex, sexual orientation, age, disability, political opinion or any other protected characteristic.

An Equal Opportunities and Diversity Policy is provided to all employees.

Disciplinary Practices

All employees are treated with dignity and respect.

The Company prohibits corporal punishment, harassment, intimidation, physical or mental coercion, verbal abuse or any other inhumane disciplinary practice.

Working Hours

Working hours comply with applicable legislation and recognised industry standards.

Normal working hours do not exceed 48 hours per week and overtime does not exceed 12 hours per week unless otherwise permitted by law or individual agreement.

The Company verifies every employee's legal right to work within the United Kingdom.

Remuneration

Employees receive pay and benefits in accordance with UK legislation.

Employment relationships are established in accordance with national law and all statutory employment rights are respected.

7. Training and Awareness

All employees are made aware of the Company's ethical labour standards during their employment.

Managers responsible for procurement, supplier management and recruitment are expected to understand the Company's commitment to preventing modern slavery and to raise concerns where unethical labour practices are suspected.

The Company will continue to review opportunities to enhance modern slavery awareness training as part of its continual improvement programme.

8. Measuring Effectiveness

TRB Chemedica (UK) Ltd monitors the effectiveness of its approach by:

  • Reviewing this statement and supporting policies annually.
  • Monitoring supplier compliance with Company expectations.
  • Investigating any concerns regarding unethical labour practices.
  • Reviewing corrective actions where required.
  • Considering modern slavery risks during management review meetings.

The Company is committed to continually improving its systems for identifying and managing modern slavery risks.

9. Approval

This Modern Slavery and Human Trafficking Statement has been approved by the Board of Directors of TRB Chemedica (UK) Ltd and will be reviewed annually.

Signed:

Mr Ben Dingwall
Managing Director
TRB Chemedica (UK) Ltd
Date: 01/07/2026