Anti-Slavery and Human Trafficking policy   Modern slavery is a crime and a violation of fundamental human rights. It can take many forms such as forced and compulsory labour, servitude, slavery, and trafficking. Vision Pharmaceutical Ltd (trading as Spectrum) and all its associated business entities are committed to acting ethically and with integrity in all its business dealings and in all its relationships and to this end are committed to efforts against Modern Slavery. The Company acknowledges that every supplier and employee deserves the right to live and work with dignity and respect, in reasonable and safe conditions and earn a fair income. The Company has a responsibility to ensure respectable social and ethical practices within its own operations and within its supply chain. These practices are governed by our code of conduct policy. This policy sets out Vision Pharmaceutical Ltd (trading as Spectrum) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its business and in its supply chains. Vision Pharmaceutical Ltd (trading as Spectrum) maintains relationships with many different organisations, suppliers, contractors, as well as with its own employees. The Company is committed to and compliant with the general law on employment and human rights and more specifically, the Modern Slavery Act 2015.   Organisational Structure and Supply Chains This policy covers all the activities of Vision Pharmaceutical Ltd (trading as Spectrum) and its associated businesses. It governs all its business dealings and the conduct of all persons or organisations with whom it contracts directly or who it appoints to act on its behalf. The Company expects all who have, or seek to have, a business relationship with Vision Pharmaceutical Ltd (trading as Spectrum) and / or any division associated to the business, to familiarise themselves with the Company’s Anti-Slavery and Human Trafficking policy and to always act in a way which is consistent with it. Vision Pharmaceutical Ltd (trading as Spectrum) sources both direct finished goods for resale and indirect services. Business Managers and the Procurement and Commercial departments follow a standardised sourcing process for the identification, selection, and management of suppliers to the Company. This is risk managed via the Company supplier set-up process and controlled by the Quality & Compliance department. As part of this process, and to ensure obligations are met under the UK Modern Slavery Act 2015, candidate suppliers must meet pre-qualification criteria, in order to be considered for a commercial relationship. One of these criteria is the capability to provide evidence of both the existence of and implementation of a Anti Modern Slavery policy and to be prepared to have the implementation of this policy audited. This is a dynamic process, by which the Procurement and Quality & Compliance departments monitor to ensure ongoing compliance.   Responsibility The Quality & Compliance department ensures that all employees are aware and understand this policy. Vision Pharmaceutical Ltd (trading as Spectrum) and its Procurement and Quality & Compliance departments are responsible for ensuring that all dealings with suppliers, whether contractual or not, comply with this policy. Vision Pharmaceutical Ltd (trading as Spectrum) adheres to its Diversity and Equal Opportunities policy and fully supports the principles of equal opportunities in employment and opposes all forms of discrimination on the grounds of gender, race, ethnic origin, sex, marital & family status, age, sexual orientation, disability, and political or religious belief. Vision Pharmaceutical Ltd (trading as Spectrum) mandates all departments adhere to recruitment practices that ensure that all terms of employment are voluntary. The Company conducts its own recruitment activities and only uses reputable employment agencies to source labour and conduct appropriate background checks. Where necessary and if required, the Company may request demonstration of compliance with this policy. All recruitment activities follow a detailed process to ensure every candidate is treated appropriately from a legal and welfare perspective. Where Vision Pharmaceutical Ltd (trading as Spectrum) deals with suppliers who manufacture products outside of the UK, the Company ensures that that these suppliers comply with all local legislation regarding Ethical Trading and Modern Slavery. This is identified through the pre-qualification criteria as part of the supplier sourcing process. All suppliers are expected to familiarise themselves with the Company’s Anti-Slavery and Human Trafficking policy and to act at in a way which is consistent with this policy at all times. If local legislation differs from this statement, the Company will encourage best practice and changes to supplier processes and offer support to the supplier on how it might achieve compliance. Vision Pharmaceutical Ltd (trading as Spectrum) response to, and reporting of, concerns raised in relation to suppliers from outside of the UK will be tailored to the local circumstances, legislation, organisations, and support mechanisms present in that country. Vision Pharmaceutical Ltd (trading as Spectrum) encourages all employees to report any concerns related to the direct activities of the organisation or its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s confidential reporting procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees who have concerns can refer, confidentially, to the Company’s whistleblowing officers identified in our whistleblowing policy, or through the Company’s external whistleblowing service, https://report.whistleb.com/en/addlife#;   Due Diligence On an annual basis, the Quality & Compliance department will review the progress of all required training on this policy. In addition, the Company will raise awareness of modern slavery issues by making it available on the Company website for customers and employees. The Company expect employees to refer to this policy and understand what is required of them in relation to modern slavery. Vision Pharmaceutical Ltd (trading as Spectrum) will make this policy statement available to members of the public and other interested parties on the Company’s website https://www.healthcare21.eu/. Stephen Arundel UK Managing Director Vision Pharmaceutical Ltd (trading as Spectrum) Updated July 2024