Modern slavery policy

Newfoundland Diagnostics Ltd (“Newfoundland”) and its group companies.

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 taking reasonable steps to ensure modern slavery is not taking place in our business or in 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 compliance with the Modern Slavery Act 2015 and to respecting 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, seconded workers, volunteers, and interns. We expect our suppliers to meet the same standards.

Newfoundland Diagnostics Ltd supplies diagnostic tests and testing services, including self-test kits and laboratory testing, to customers in the UK and internationally. We operate through our UK company and group companies in other countries.

Our supply chain includes manufacturers of test kits (several of them overseas), UK laboratory partners that process samples, couriers and logistics providers, and IT and professional service providers. We work with our suppliers to encourage compliance with this policy.

The board of directors holds overall responsibility for ensuring this policy complies with our legal and ethical obligations. Day-to-day responsibility sits with our senior management team, who are responsible for implementation, risk assessment and supplier engagement regarding modern slavery.

We take a proportionate approach to due diligence, based on the level of risk. This includes carrying out appropriate checks when engaging new staff and suppliers, and including modern slavery requirements in our supplier contracts where appropriate.

We consider the risk of modern slavery when selecting and reviewing suppliers, with particular attention to suppliers in industries or countries where the risk is known to be higher. We review our key suppliers periodically.

We keep the effectiveness of our approach under review, including staff awareness, engagement with suppliers, any concerns raised, and any action taken in response. The board reviews this statement annually.

We make our employees aware of modern slavery, including how to identify the signs, the risks it poses to businesses, and how to report concerns. We share this policy with our key suppliers and encourage them to raise awareness among their own staff.

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 should report any concerns regarding modern slavery to their manager or their main contact at Newfoundland, or directly to us at info@newfoundland.io. Concerns can also be raised with the Modern Slavery and Exploitation Helpline on 08000 121 700. We encourage openness and transparency, and no one will suffer any detrimental treatment for reporting concerns in good faith.

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

This statement has been approved by the board of directors of Newfoundland Diagnostics Ltd on 29th October 2026 and will be reviewed annually.

Signed: Michael Hodnett, Director

Dated: 29th October 2026