Ethical sourcing policy

1. Introduction

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 outlines our
commitment to sourcing materials, products, and services from suppliers that
uphold the highest ethical standards, in compliance with UK legislation such
as the Modern Slavery Act 2015, Bribery Act 2010, and environmental
regulations.

1.2. This policy is designed to help us meet the expectations for responsible
business conduct in line with the Public Contracts Regulations 2015, ensuring we are legally compliant and competitive in government procurement processes.

2. Purpose

2.1. The purpose of this policy is to:
2.1.1. Ensure that all products and services procured by Newfoundland are sourced responsibly, ethically, and sustainably.
2.1.2. Demonstrate our compliance with UK laws related to modern slavery, bribery, environmental protection, and labour standards.
2.1.3. Set clear standards for our suppliers to prevent unethical practices
such as child labour, forced labour, environmental harm, and corrupt
practices.

3. Scope

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, ensuring
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.

4. Key Issues Addressed:

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

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

4.3. Environmental Sustainability: Compliance with environmental regulations,
promoting the use of sustainable and recycled materials where possible, and
minimizing the environmental impact of our supply chain.

5. Ethical Sourcing Principles

5.1. Our suppliers and subcontractors are expected to adhere to the following
principles:
5.1.1. Human Rights:
5.1.1.1. Suppliers must ensure that no forced labour, child labour, or
human trafficking is involved in any part of the supply chain.
5.1.1.2. Suppliers must comply with the Modern Slavery Act 2015 and
take steps to identify and mitigate risks of modern slavery.
5.1.1.3. Fair wages and safe working conditions must be provided to all
workers.

6. Bribery and Corruption:

6.1. Suppliers and subcontractors must comply with the Bribery Act 2010 and
have effective anti-bribery measures in place.
6.2. Any form of bribery, corruption, extortion, or unethical business practice is
strictly prohibited.
6.3. Suppliers must report any attempts at bribery or corrupt practices
encountered during the course of their work with Newfoundland.

7. Environmental Responsibility:

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

7.2. Where possible, suppliers should use recycled materials and promote closed-loop recycling processes.

7.3. Compliance with environmental regulations is mandatory throughout the
supply chain.

8. Labour Practices:

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

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

8.3. Workers must be treated with respect

9. Supplier Expectations and Compliance

9.1. As part of our ethical sourcing process, suppliers are required to:
9.1.1. Agree to our ethical sourcing terms and conditions as part of their
contract.
9.1.2. Demonstrate compliance with all applicable laws, including the Modern
Slavery Act 2015, Bribery Act 2010, and environmental legislation.
9.1.3. Implement internal procedures to monitor compliance with these
requirements across their operations and supply chains.
9.1.4. Provide documentation or evidence upon request to demonstrate
compliance with ethical standards.

9.2. If suppliers subcontract any part of their work, they must ensure that the
subcontractor also complies with this policy and the relevant laws. Any
violations or potential breaches of this policy must be reported to
Newfoundland immediately.

10. Monitoring and Auditing

10.1. Newfoundland reserves the right to audit its suppliers to ensure
compliance with this policy. Audits may include:
10.1.1. Reviewing supplier facilities and documentation.
10.1.2. Conducting interviews with supplier personnel.
10.1.3. Inspecting records related to labour practices, environmental
performance, and anti-corruption measures.

10.2. If a supplier is found to be in violation of this policy, corrective actions
will be required, and failure to comply may result in the termination of the
supplier relationship.

11. Reporting Concerns

11.1. Suppliers and subcontractors are encouraged to report any concerns
regarding ethical sourcing practices. This can be done through Newfoundland’s whistleblowing policy, which ensures confidentiality and protection from retaliation. Concerns may include:

11.1.1. Suspected human rights violations, such as forced labour or child
labour.
11.1.2. Potential environmental violations, such as pollution or unsustainable
sourcing.
11.1.3. Any attempts to bribe or engage in corrupt practices.

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

12. Legal and Government Compliance

12.1. This policy helps ensure Newfoundland complies with key UK
legislation, including:
12.1.1. Modern Slavery Act 2015
12.1.2. Bribery Act 2010
12.1.3. Environmental Protection Act 1990
12.1.4. Public Contracts Regulations 2015

13. Policy Governance

13.1. This policy is governed by the Board of Newfoundland, and the ultimate
responsibility lies with the Directors. Compliance with this policy is mandatory
for all employees, contractors, and suppliers. The policy will be reviewed to
ensure its continued relevance and compliance with evolving laws and
regulations.

14. Policy Review and Monitoring

14.1. This policy will be reviewed by the Board of Directors to ensure it
remains effective and compliant with UK legislation. Supplier compliance will
be monitored through audits, feedback, and reporting mechanisms to ensure
adherence to ethical standards.

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Frequency of Review: 2 Years
Approved by Freddie Jackson – Head of Operations
Date: 14.07.2024