Apos Medical UK Modern Slavery Policy

1. Introduction
Apos Medical UK is committed to preventing modern slavery and human trafficking in all aspects of our business and supply chains. We understand our responsibility to uphold ethical standards and comply with relevant laws, including the Modern Slavery Act 2015. This policy outlines our commitment to combating modern slavery and our approach to achieving this goal. It is reviewed annually and changes are incorporated accordingly.

2. Our Business
Apos Medical UK is a medical equipment and services provider. We operate in accordance with UK law and respect the human rights of all individuals involved in our business operations. In order to provide its services, Apos Medical Assets (the parent company) designs its product and components internally within the company and has them made externally. The software is designed internally. Apos Medical Assets relies on supply chains such as courier and shipping companies to transfer stock to Apos Medical UK. Stock is housed within UK Apos providers to meet patient requirements.

3. Our Supply Chains
We recognise that the risk of modern slavery may exist in the supply chains that support our business. We are committed to working with suppliers and partners who share our commitment to ethical and responsible practices.

4. Policy Statements
4.1. Prohibition of Modern Slavery
Apos Medical UK strictly prohibits all forms of modern slavery, including but not limited to forced labour, child labour, debt bondage, and human trafficking. We do not tolerate any such practices within our organisation or our supply chains.

4.2. Due Diligence
We will undertake due diligence to assess and mitigate the risks of modern slavery in our supply chains. This includes conducting risk assessments, evaluating suppliers, and implementing corrective actions where necessary. The Chief Officer in relation to the specific supply chain and the Procurement Managers are responsible for conducting the risk assessments.

4.3. Supplier Responsibility
We expect our suppliers and business partners to adhere to the same principles and standards set out in this policy. We will work with them to ensure that modern slavery is not present within their own operations.

4.4. Employee Awareness and Training
Apos Medical UK will provide training and raise awareness among our employees to recognise and prevent modern slavery. We encourage employees to report any concerns regarding potential slavery or human trafficking within the organisation or our supply chains. Apos Medical UK strives to maintain the highest standards of employee conduct and ethical behaviour. This information is accessible in our Employee Handbook.

4.5. Reporting Mechanism
We have established a reporting mechanism for employees and external stakeholders to report any suspicions or concerns related to modern slavery. Reports can be made confidentially and without fear of reprisal.

4.6. Compliance and Consequences
Failure to comply with this policy may result in disciplinary action, including termination of employment or the termination of business relationships with suppliers and partners found to be involved in modern slavery.

5. Review and Improvement
Apos Medical UK is committed to regularly reviewing and improving this policy to ensure its effectiveness in combating modern slavery. This policy will be reviewed annually to reflect changes in legislation, best practices, and our evolving understanding of modern slavery risks.

6. Approval and Adoption
This policy has been approved by the Board of Directors and will be communicated to all employees, suppliers, and business partners. This version is effective from 6/11/2023.

7. Contact Information
If you have any questions or concerns related to this policy or suspect any violations of it, please contact [email protected].

Sachin Gohil
Chief Commercial Officer