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Modern slavery and Human Trafficking Statement

January 2024

Introduction

This statement is made on behalf of Scarboroughs Health Ltd pursuant to the section 54(1) of the Modern Slavery Action 2015 and comprises our slavery and human trafficking statement.

Our Business

Our business centred in the United Kingdom brings together product sales direct to domestic UK based acupuncture practitioners, larger organisations (ie NHS, MOD), specialist acupuncture training facilities, international sales and re-seller channels.

Our Supply Chains

ur supply chain is direct supply to our customer base of acupuncture supplies, in the UK and throughout the world. Our supplies are sourced from a variety of manufacturers and distributors, whose manufacture is based mainly in Asia or near Europe. Scarboroughs commission their own product manufacture via factories and organisations in The Republic of China. Other finished products are sourced direct from distributors based in the Republic of China or Japan. Most branded goods are bought direct from licenced distributors within Europe.

Supply chain verification

The company’s policy is to evaluate potential contracted factories before they enter the supply chain to assess compliance with standards including country-related risk for issues including force labour, human trafficking and slavery. They use both internal and external third-party audits. Direct suppliers’ certification of materials – The company is working on mapping and understanding impacts further up the supply chain, to develop standards for upstream suppliers of contracted manufacturers. Standards for compliance - If a contracted factory is found to violate laws or the manufacturer’s standards, it is responsible for improving performance against a master action plan. If the factory fails to make progress against that plan, they are subject to review and sanctions, including potential termination. Scarboroughs’ policy is to uphold the supply of CE accredited products only manufactured under strict adherence to ISO 9001 standards.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all of our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business and supply chains.

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify risk and mitigate against such risks, we nominate senior representations of the business We have in place systems in our business and our supply chains to: • Identify inappropriate employment practices • Identify and assess other potential risk areas • Mitigate the risk of slavery and human trafficking occurring • Monitor potential risk areas • Protect Whistleblowers

Measuring Effectiveness – Supplier Adherence to our values and ethics

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we operate in line with principles of responsible sourcing, including paying employees at the prevailing minimum wage applicable.

Training

To ensure a high a high level of understanding of the risks of modern slavery and human trafficking in our business, in our supply chains and in our business partners, we provide relevant training to our staff.

Anti-slavery and human trafficking policy

Policy Statement This policy applies to all persons working for Scarboroughs Ltd or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers. Scarboroughs Ltd strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Commitments

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery: • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains. • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy. • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain. • We take a risk based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking. • Consistent with our risk based approach we may require: employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code • As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct. • If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action.