Modern Day Slavery Policy

This policy has been reviewed in March 2023 and relates to the Financial Year 2023.

Ardo medical Ltd (Ardo) is committed to driving out acts of modern-day slavery and human trafficking within its business and from within its supply chains, including sub-contractors, and partners.

Ardo has a zero-tolerance approach to slavery and human trafficking and upholds the spirit and intentions of the Modern Slavery Act 2015. The Ardo Modern-Day slavery policy reflects our promise to act ethically, and with integrity in all our business relationships. We implement and enforce effective systems and controls to ensure slavery and human trafficking are not occurring anywhere in our supply chains.

We will ensure transparency within the Company and suppliers of goods and the larger supply chain and services to the Company through steps which include:

• Assessing and reducing the risk in the business of modern slavery practices occurring e.g., checking the authenticity of papers proving a right to work in the UK
• Having robust procurement policies that ensure our supply chain is scrutinised for compliance and consequences of non-compliance are clear and actioned i.e., that commercial relationships with suppliers, contractors and other business partners will not be entered into (or terminated if existing)
• Providing information to staff on the warning signs that might indicate that modern slavery is taking place
• Promoting to staff the importance of raising immediately any concerns they may have
• Protecting staff who are ‘whistle blowers’ in respect of concerns they have about modern slavery

When we appoint new contractors or suppliers, we pre-qualify them through a due diligence process. We look at company performance and get references from other customers to establish that they are suitable.

To date, we have not been made aware of any human trafficking or slavery activities within the supply chain. However, if any were highlighted to us, we would act immediately in accordance with our legal and moral obligations.

Due diligence

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence and reviews include:

• evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment]
• Regularly review their existing supply chains
• Mitigate the risk of slavery and human trafficking occurring in their supply chains
• Monitor potential risk areas in their supply chains.
• Protect whistle-blowers.

Freek Vierling
Managing Director

For and on behalf of Ardo medical Ltd.
Revised: March 2023