Ethical sourcing policy

1.1. At Newfoundland Diagnostics Ltd (“Newfoundland”) we are committed to ethical sourcing as a core part of our business practices. We believe that sourcing ethically is essential to building sustainable business relationships and supporting the communities in which we operate. This policy sets out our commitment to sourcing materials, products, and services from suppliers that uphold high ethical standards, and our approach to doing so in line with UK legislation such as the Modern Slavery Act 2015, the Bribery Act 2010, and environmental regulations.

1.2. This policy forms part of our wider approach to responsible business conduct, alongside our Modern Slavery and Human Trafficking Statement and our Whistleblowing Policy.

2.1. The purpose of this policy is to:

2.1.1. Support the responsible, ethical, and sustainable sourcing of the products and services procured by Newfoundland.

2.1.2. Support our compliance with UK laws relating to modern slavery, bribery, environmental protection, and labour standards.

2.1.3. Set clear standards for our suppliers to help prevent unethical practices such as child labour, forced labour, environmental harm, and corrupt practices.

3.1. This policy applies to all employees, contractors, consultants, suppliers, and subcontractors. It covers:

3.1.1. The ethical procurement of products and services, supporting compliance with applicable laws and regulations.

3.1.2. Supplier responsibilities to uphold human rights, environmental protection, and fair labour practices.

3.1.3. Prevention of corruption, bribery, and unethical business practices across the supply chain.

3.2. We recognise that many of our suppliers operate outside the UK. We expect them to comply with the laws that apply where they operate and to meet standards consistent with this policy.

4.1. Human Rights: Supporting compliance with the Modern Slavery Act 2015 and prohibiting forced labour, child labour, and human trafficking.

4.2. Bribery and Corruption: Supporting compliance with the Bribery Act 2010, and expecting that no supplier or subcontractor engages in corrupt practices, including bribery, extortion, or collusion.

4.3. Environmental Sustainability: Supporting compliance with environmental regulations, promoting the use of sustainable and recycled materials where practicable, and minimising the environmental impact of our supply chain.

5.1. Our suppliers and subcontractors are expected to adhere to the following principles.

Human Rights

5.1.1. Suppliers must not use forced labour, child labour, or human trafficking in any part of their operations or supply chain.

5.1.2. Suppliers must comply with the Modern Slavery Act 2015 where it applies to them and, in any case, take reasonable steps to identify and mitigate the risk of modern slavery in their operations and supply chains.

5.1.3. Fair wages and safe working conditions must be provided to all workers, in line with applicable law.

Bribery and Corruption

5.2.1. Suppliers and subcontractors must comply with the Bribery Act 2010 where it applies to them and with the anti-bribery laws of the countries where they operate, and must have appropriate anti-bribery measures in place.

5.2.2. Any form of bribery, corruption, extortion, or unethical business practice is strictly prohibited.

5.2.3. Suppliers must report any attempts at bribery or corrupt practices encountered in the course of their dealings with Newfoundland.

Environmental Responsibility

5.3.1. Suppliers are expected to minimise their environmental impact by using sustainable resources, reducing waste, and preventing pollution.

5.3.2. Where practicable, suppliers should use recycled materials and support closed-loop recycling.

5.3.3. Suppliers must comply with the environmental laws that apply to them.

Labour Practices

5.4.1. Suppliers must ensure that their employees and subcontractors work under conditions that respect their health, safety, and dignity.

5.4.2. Discrimination, harassment, and exploitation in any form are not tolerated.

5.4.3. Workers must be treated with respect.

6.1. As part of our ethical sourcing process, we expect suppliers to:

6.1.1. Where appropriate, agree to ethical sourcing terms as part of their contract.

6.1.2. Comply with the laws that apply to them, including where applicable the Modern Slavery Act 2015, the Bribery Act 2010, and environmental legislation, and not act in a way that would cause Newfoundland to breach UK law.

6.1.3. Take reasonable steps to monitor compliance with these requirements across their operations and supply chains.

6.1.4. Provide information or evidence on reasonable request to demonstrate compliance with these standards.

6.2. If suppliers subcontract any part of their work, they should ensure that the subcontractor meets the same standards. Suppliers should tell Newfoundland promptly of any actual or suspected breach of this policy.

7.1. Newfoundland may take proportionate steps to check supplier compliance, which can include requesting documentation and, where appropriate and permitted by our contract with the supplier, carrying out audits. These checks may include:

7.1.1. Reviewing supplier documentation and facilities.

7.1.2. Speaking with supplier personnel.

7.1.3. Reviewing records relating to labour practices, environmental performance, and anti-corruption measures.

7.2. If a supplier is found to be in breach of this policy, we will require corrective action. If the supplier fails to comply, we may end the relationship.

8.1. Suppliers, subcontractors, and employees are encouraged to report any concerns regarding ethical sourcing practices. This can be done through Newfoundland’s Whistleblowing Policy, which provides for confidentiality and protection from retaliation, or by email to info@newfoundland.io. Concerns may include:

8.1.1. Suspected human rights violations, such as forced labour or child labour.

8.1.2. Potential environmental violations, such as pollution or unsustainable sourcing.

8.1.3. Any attempts to bribe or engage in corrupt practices.

8.2. Reports should include relevant details, evidence, and any steps already taken to address the issue.

9.1. This policy supports Newfoundland’s compliance with key UK legislation, including:

9.1.1. Modern Slavery Act 2015

9.1.2. Bribery Act 2010

9.1.3. Environmental Protection Act 1990

9.2. If a customer, including a public sector body, asks about our ethical sourcing arrangements, we will provide this policy on request.

10.1. This policy is governed by the Board of Newfoundland, and ultimate responsibility lies with the Directors. Compliance with this policy is expected of all employees, contractors, and suppliers. This policy does not itself create contractual rights or obligations. Obligations on suppliers arise under their contracts with Newfoundland.

10.2. This policy will be reviewed annually by the Board to ensure it remains effective and compliant with UK legislation. Supplier compliance will be monitored through the checks, feedback, and reporting described in this policy.

Frequency of Review: Annually
Approved by Michael Hodnett, Director
Date: 29th October 2026