The SureScreen Group Transparency in Supply Chain

Including Modern Slavery, Forced Labour and Human Trafficking policy Statements

Last Updated: 20 July 2022

Introduction

The SureScreen Group (encompassing SureScreen Diagnostic, SureScreen Scientifics and Nutrivitality) has a zero-tolerance approach to modern slavery and is committed to ensuring there is no modern slavery, forced labour or human trafficking in any part of our businesses, including our supply chains. The Company is committed to acting ethically and with integrity in all our business dealings and relationships.

Modern slavery is a terrible crime, an act of moral disgrace and a violation of fundamental human rights. Modern slavery denies an individuals' independence and pride purely for other individuals' gain. Modern slavery is a real problem for millions of people all around the world.

This includes developed countries where people are being exploited in various forms of slavery, including but not limited to slavery, servitude, forced and compulsory labour and human trafficking. Every Company is at risk of being involved with this crime through its own operations and its supply chain.

The SureScreen Group has a zero-tolerance approach to modern slavery in any form throughout our operations and supply chain.

Aim:

The aim of this policy statement and supporting policy documents is to demonstrate that The SureScreen Group and Surescreen Diagnostics follows best practice and that all reasonable steps are taken to prevent modern slavery, forced labour and human trafficking.

Background:

SureScreen Diagnostics are an award-winning manufacturer and distributor of medical devices, predominantly in the immunoassay rapid test sector.

Specialising in diagnostic health testing and modern point-of-care diagnostics, Surescreen Diagnostics supplies high-quality market-leading products, including COVID19 Lateral Flow tests, to over 53 countries around the world. The SureScreen Group also includes access to UKAS laboratory facilities and operates dedicated laboratories focusing on Life Science and Forensic Investigation industries.

We are an equal opportunities employer and do not discriminate on the grounds of gender, sexual orientation, marital or civil partner status, gender reassignment, race, colour, nationality, health condition, ethnic or national origin, religion or belief, disability or age.

The countries The SureScreen Group sources its good or services from:

Surescreen Diagnostics primarily sources manufacturing materials/ products sourced from key suppliers located in the United Kingdom, United States, Europe and ROW.

Make up, and complexity of the supply chains used (Summary):

Our generic supply chain begins with identifying responsible supply partners who adhere to recognised quality production standards. With our supply partners in place, raw materials, components etc., are sourced by our dedicated procurement team, who in turn make arrangements for our approved logistics providers to schedule the shipment of goods to our UK production facilities.

Upon receipt of the aforementioned materials, quality inspections are undertaken to ensure product quality and integratory before the manufacturing process commences to produce the finished product.

Upon completion of the manufacturing process, further quality assessments are completed in accordance with recognised quality management accreditations (ISO, CE) before the secure warehousing and the onward distribution of finished goods to wholesale sale and direct Client accounts.

This simplified process completes the supply chain cycle, but it's the demand that then goes back and drives further production, and the cycle continues.

The Business Operating Model:

Surescreen Diagnostics adopts a unification style of operating model, which is based on a globally integrated set of business processes where customers and suppliers are distributed geographically. Business units have similar operations where processes and data are designed centrally so they can be shared. Centralised management of these processes typically leverages a matrix approach to keep track of the business unit composition. Although the business units have distinct operations, high-level business process owners work to standardise business processes across the business units.

Our Company Responsibility and Supply Chains:

The SureScreen Group is responsible for ensuring this policy statement complies with all legal and ethical obligations and all individuals associated with the Group adhere to the policy statement. The Company has primary and day-to-day responsibility for implementing this policy statement, including monitoring its use and effectiveness and responding to any queries regarding it.

Management are responsible for ensuring all reportees understand and comply with this policy statement.

We establish a relationship built on trust and integrity with all our suppliers, established on mutually beneficial factors. Our supplier selection and on-boarding procedures include the due diligence of the reputation of suppliers, respect for the law, compliance with Health, Safety and Environmental standards, and references.

We are committed to acting ethically, with integrity and displaying transparency throughout The SureScreen Group in all business dealings and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same standards from our contractors, suppliers, and other business partners.

Identities of new employees and their right to work in the United Kingdom are confirmed before the new employee joins the Company. All employees are remunerated at or above the National Living Wage. Employees are not forced to work in excess of the hours they have agreed to and are permissible by the Working Time Regulations 1998. Any overtime worked must be voluntary unless contractually agreed with agreed remuneration for this.

We have not been made aware of any allegations of modern slavery activities, including forced labour or human trafficking against any of our suppliers. If this were to change, we would act immediately against the supplier and report it to the authorities.

This policy statement applies to all individuals working for us or on behalf of us in any capacity. This includes but is not limited to employees at all levels, directors, agency workers, interns, contractors, external consultants, and third-party representatives.

Employees:

All employees are encouraged to read, understand, and comply with this policy statement.

All employees are responsible for contributing to the successful prevention of modern slavery, forced labour and human trafficking.

All employees are responsible for being alert to the risks in our business and wider supply chains.

Employees understand they are required to avoid any activity which may lead to or suggest a policy statement breach, and they must notify their manager or a director as soon as they believe or suspect a conflict with this policy statement has occurred or may do so.

Employees must raise concerns about any challenge or suspicion of modern slavery in any format across any part of the Company or supply chain as early as possible. Management are expected to act upon these concerns.

The SureScreen Group operates the following policies for identifying and preventing slavery, forced labour and human trafficking:

  • Whistleblowing Policy ‐ we encourage all employees, customers, and suppliers to report any suspicion of slavery or human trafficking without the fear of retaliation.
  • Code of Conduct ‐ Our Code encourages all employees to do the right thing by clearly stating the actions and behaviour expected of them when they are representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating.
  • Recruitment policy ‐ we operate a robust recruitment policy, including the aforementioned eligibility checks for the right to work in the UK for all employees to safeguard against modern slavery or human trafficking.

We encourage openness and support any individual who raises genuine concerns in good faith. We are committed to ensuring detrimental treatment is not experienced due to reporting in good faith. Detrimental treatment includes but is not limited to dismissal, disciplinary action, threats or any other unfavourable treatment connected to raising a concern. If you believe you suffer any such treatment, you should inform the HR Manager immediately, who will advise you of the next steps.

All employees are encouraged to comment on this policy statement and suggest any improvements to the Directors.

Engagement:

This policy applies to our employees, suppliers, sub-contractors and other business partners.

The SureScreen Group prohibits benefiting from or contributing to Modern Slavery.

Employees are aware, they have the freedom to terminate their employment, having completed an agreed notice period where relevant, without penalty.

The SureScreen Group will not knowingly work with suppliers, subcontractors or providers of services who retain identity documents, work permits or travel documents unnecessarily.

The SureScreen Group does not condone the use of any harsh or inhumane treatment. Disciplinary and grievance procedures and processes should be clearly defined and communicated to all.

Awareness:

The SureScreen Group raises awareness of modern slavery by displaying information across all of our business sites. This policy statement is also shared annually and is available on the HR System, BambooHR, for employee review at any time.

Training:

Human Trafficking and Modern Slavery Training is available online via High-Speed Training, an online training provider used throughout the Company for various training courses. The training is accredited by the Continuing Professional Development (CPD) Certification Service. The training provides learners with an awareness of the exploitation signs. Best practice methods are taught throughout the training for talking to victims and understanding the barriers preventing potential victims from trusting authorities and cooperating with them. The training also shows how victims are trafficked, what makes individuals vulnerable to trafficking and how to support victims and make accommodations for the effects of trauma experienced. Ideally, training will be renewed every three years.

Breaches of this Policy Statement:

Any employee who breaches this policy statement will face disciplinary action, resulting in dismissal for misconduct or gross misconduct should a thorough investigation deem this an appropriate course of action. We may terminate our working relationship with other individuals and organisations working on our behalf if they breach this policy.

This policy statement is written in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes The SureScreen Group's modern slavery, forced labour and human trafficking statement.

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