Anti-Slavery and Human Trafficking Policy

Effective as of 24 April 2025

Policy statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery — exercising powers of ownership over a person; servitude — the obligation to provide services imposed by the use of coercion; forced or compulsory labor — work or services exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily; and human trafficking — arranging or facilitating the travel of another person with a view to their exploitation. All of these forms involve the deprivation of a person’s liberty for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships, implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or among our contractors, suppliers, or other business partners.

We are also committed to ensuring transparency in our own business and in our approach to tackling modern slavery across our partner relationships, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers, and business partners and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and we expect that our business partners will hold their own business partners to the same high standards.

About this policy

The purpose of this policy is to set out our responsibilities, and those of anyone working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking, and to provide information on how to identify and report concerns regarding modern slavery and human trafficking.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, temporary workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

Responsibility for the policy

The Chief Compliance Officer has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. 

The Chief Compliance Officer has primary responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed to Compliance@medrio.com.

Your responsibilities and how to raise a concern

• You must ensure that you read, understand, and comply with this policy.
• The prevention, detection, and reporting of modern slavery in any part of our business or business partners is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
  You must notify Compliance@medrio.com as soon as possible if you believe or suspect that a breach of this policy has occurred or may occur in the future.
• You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or business partners at the earliest possible stage. 
• If you believe or suspect that a breach of this policy has occurred or that it may occur, you must notify Compliance@medrio.com as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our business partners to help them address coercive or exploitative work practices with their own business and with their business partners. 
• If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our business partner relationships constitutes any of the various forms of modern slavery, raise it with your manager or notify Compliance@medrio.com.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, and Medrio’s Open Door Policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any retaliatory treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or with any of our business partners. Retaliatory treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the VP of Human Resources immediately. All matters will be investigated according to the terms of Medrio’s grievance policy currently in place.

Training and communication

Training on this policy, and on the risk our business faces from modern slavery with its business partners, forms part of the onboarding process for all individuals who work for us, and regular training will be provided as necessary.

Our commitment to addressing the issue of modern slavery in our business and with our business partners must be communicated to all contractors, suppliers, and business partners at the outset of our business relationship with them and reinforced as appropriate on an ongoing basis.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.