Modern slavery policy

Newfoundland Diagnostics Ltd ("Newfoundland").

Policy Statement

Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person's liberty by another to exploit them for personal or commercial gain. Newfoundland is committed to acting ethically, with integrity, and with transparency in all business dealings and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

Newfoundland is committed to ensuring that all employment is freely chosen, that there is no use of forced, compulsory, or trafficked labour, and that no one is held in slavery or servitude, whether adults or children. We are committed to operating in full compliance with the Modern Slavery Act 2015 and protecting the human rights of our employees and all workers in our supply chain.

This policy applies to all persons working for or on behalf of Newfoundland in any capacity, including employees at all levels, directors, officers, agency workers, suppliers, seconded workers, volunteers, and interns.

Organisational Structure & Supply Chain

Newfoundland Diagnostics Ltd is a leading provider of diagnostic services, offering a wide range of tests and services globally. We operate in multiple countries with a diverse supply chain consisting of both local and international suppliers. We actively engage with suppliers to ensure compliance with our anti-slavery policy.

Responsibility for this policy

The board of directors holds overall responsibility for ensuring this policy complies with our legal and ethical obligations, and for ensuring that all those under our control comply with it. The Head of Compliance is responsible for day-to-day implementation, risk assessments, and supplier engagement regarding modern slavery.

Due-Diligence processes

Newfoundland operates the due diligence processes to ensure modern slavery does not occur in our business or supply chains, including audits and background checks, as well as clauses in contracts.

Risk assessment and management

To manage the risk of modern slavery, we conduct risk assessments of our supply chains, focusing on suppliers in industries or countries where modern slavery is a known risk. Suppliers are annually reviewed to ensure compliance.

Key Performance Indicators (KPIs)

To measure the effectiveness of our actions in ensuring modern slavery does not occur within our business or supply chains, Newfoundland tracks the KPIs including, supplier audits, staff training, reported incidents and any action taken. The results are reported to the board annually and inform our strategy for the following year.

Training & capacity building

All Newfoundland employees and suppliers are required to complete mandatory modern slavery training. This training includes identifying signs of modern slavery, understanding the risks it poses to businesses, and the proper channels to report concerns.

Compliance with this policy

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains are the responsibility of all individuals working for or on behalf of Newfoundland. All employees are required to avoid any activity that may lead to or suggest a breach of this policy.

Employees and suppliers must report any concerns regarding modern slavery to their manager or their main contact at Newfoundland. We encourage openness and transparency, and no one will suffer any detrimental treatment for reporting concerns in good faith.

Communication and awareness of this policy

This policy is communicated to all staff. It is also communicated to external partners to ensure a shared understanding of Newfoundland's commitment to preventing modern slavery.

Breaches of the policy

Any employee found to be in breach of this policy will face disciplinary action, which could result in dismissal for gross misconduct. We may terminate our relationship with suppliers or other third parties who fail to comply with this policy.

Approval and review

This statement has been approved by the board of directors of Newfoundland Diagnostics Ltd and will be reviewed annually to ensure its continued relevance and effectiveness.

Dated: 7th August 2024

Michael Hodnett – Director