Modern Slavery Policy

1. Purpose
The purpose of this policy is to describe the commitment of Medinox London Limited to help eradicate modern slavery and human trafficking wherever it exists. Our annual statement will provide information to supplement this policy, including details of our activities, supply chains and the actions we are taking to support the eradication of modern slavery and human trafficking.
2. Scope
This policy applies to all individuals working for Medinox London Limited or any Medinox London Limited Group Company in any capacity. It also applies to shareholders and directors.
3. Our commitment
Medinox London Limited adopts a zero-tolerance approach to modern slavery, human trafficking and any form of bribery and corruption, directly and indirectly, associated with these criminal acts. We are committed to acting ethically in all our business dealings and relationships, and to implementing and enforcing effective processes and controls to ensure modern slavery is not taking place in our business or in any of our supply chains. We fully support the eradication of modern slavery and human trafficking.
We take our responsibilities to combat modern slavery in our supply chain seriously:
• Appropriate due diligence is performed on suppliers, which is informed by the nature of a procurement and the goods/services to be delivered.

• We actively monitor organisations, and protects workers’ rights

• Our standard contracts require suppliers to warrant that all times during the term of the contract they, their subcontractors and suppliers, comply with Modern Slavery Legislation and in line with Medinox London Limited’s approach as outlined in our annual statement. We require suppliers to notify Medinox London Limited as soon as they become aware of any actual or suspected slavery or human trafficking in a supply chain which has a connection with the contract.

Procurement staff receive regular training on modern slavery issues.
The prevention, detection, and reporting of modern slavery in any part of our business and supply chains is the responsibility of all of us working across the organisation:
• We expect everyone to raise any concerns about modern slavery, through their manager or using whistleblowing if necessary and will support anyone who reports concerns in good faith.

• Staff policies are in place to ensure that we act upon our commitment to eradicate modern slavery and human trafficking, including responsible recruitment, dignity at work and a pay framework. We believe in Living Wage Remuneration.

We will not work with any suppliers that do not reach the standards required through our due diligence or audit processes.
Any indication of a failure to meet required standards either before or during the life of a contract will be reported to the necessary authorities (e.g. https://www.modernslaveryhelpline.org/, or the police if immediate danger is perceived).

• Anti-bribery and corruption policy

4. Communications and training
This policy will be shared with all staff and included in the list of policies that new starters are expected to read and accept.
A training module on Modern Slavery is available for all staff in our Quality Management System training section.

5. Contact and further information
The responsibility for monitoring this policy rests with the Regulatory team. The policy will be reviewed annually and updated when Medinox London Limited deem it necessary or when legislation changes.
Questions and disclosures should be sent to the Regulatory team (customercare@medinox.co.uk)

6. Related policies and guidance
• Anti-bribery and corruption policy

Appendix 1: Process and Responsibilities
How to report a concern
Any indication of a failure to meet required standards either before or during the life of a contract should be raised with the Regulatory (customercare@medinox.co.uk ) and will be reported to the necessary authorities (e.g. https://www.modernslaveryhelpline.org/).
If immediate danger is perceived, individuals should contact the police directly and advise the Governance team that they have done so.
Responsibilities
The Regulatory team is responsible for:
1. Explaining the Modern Slavery policy and taking steps to positively promote it;

2. Providing support and guidance to individuals and people managers;

3. Being responsive and supportive to any individual who seeks guidance;

4. Ensuring that training is available to all staff and all staff have access to this policy and related processes;

5. Encouraging employees to be vigilant and to report any concern as outlined above;

6. Maintaining confidentiality in all cases;

7. Seeking advice from the Managing Director as necessary;

8. Monitoring and updating this policy as necessary.

Individuals are responsible for:
1. Ensuring that they read, understand and comply with this policy;

2. Being vigilant and reporting any concerns as outlined above.

People managers are responsible for:
1. Raising awareness of this policy.
The Regulatory team is responsible for:
1. Raising awareness of this policy to new starters at the time of induction.