Modern Slavery and Human Trafficking Policy

Purpose

This policy sets out Cambridge Life Sciences’ commitment to preventing modern slavery, forced labour, human trafficking, and exploitation in all aspects of our business operations and supply chains. As an ISO 13485 certified medical device business, we recognise our responsibility to uphold human rights while ensuring ethical, compliant, and responsible sourcing.

This policy supports compliance with the UK Modern Slavery Act 2015, ISO 13485 requirements relating to supplier control, and internationally recognised human rights standards, including the UN Guiding Principles on Business and Human Rights.

Scope

This policy applies to:

• All employees, directors, and officers of Cambridge Life Sciences (approximately 13 employees)
• Temporary workers, contractors, and consultants engaged by the business
• All suppliers, subcontractors, and service providers supporting regulated and non-regulated activities
• All business activities and operations carried out by or on behalf of Cambridge Life Sciences

Policy Statement

Cambridge Life Sciences has a zero-tolerance approach to modern slavery and human trafficking. We are committed to:

• Acting ethically and transparently in all business dealings
• Implementing and enforcing effective systems and controls to mitigate the risk of modern slavery
• Ensuring that slavery and human trafficking do not take place in our own operations or supply chains

Definitions

• Modern Slavery: Encompasses slavery, servitude, forced or compulsory labour, and human trafficking.
• Human Trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons by means of threat, force, coercion, or deception for the purpose of exploitation.
• Forced Labour: Any work or service extracted from a person under threat or coercion and for which the person has not offered themselves voluntarily.
• Roles and Responsibilities

Senior Management

• Overall accountability for compliance with this policy
• Ensuring adequate resources are available to manage modern slavery risks
• Approval of this policy and review every three years

Quality & Regulatory / Compliance Function

• Integration of modern slavery considerations into the ISO 13485 Quality Management System
• Oversight of supplier approval, monitoring, and re-evaluation activities
• Maintenance of relevant records and evidence

Managers

• Ensure this policy is communicated and understood within their teams
• Identify and escalate any concerns related to modern slavery

Employees

• Comply with this policy and associated procedures
• Remain vigilant to indicators of modern slavery
• Report concerns in line with this policy

Procurement and Supplier Management

• Assess and manage modern slavery risks within supply chains
• Ensure appropriate contractual controls are in place

Risk Assessment and Due Diligence

Given the size and risk profile of Cambridge Life Sciences, a proportionate and risk-based approach is applied. Modern slavery risks are assessed primarily through existing ISO 13485 supplier controls, including:

Supplier approval and evaluation processes

• Risk-based supplier classification (e.g. critical suppliers, service providers)
• Supplier declarations or contractual commitments regarding ethical labour practices
• Consideration of geographic and industry-specific risks

Enhanced due diligence may be applied where higher risks are identified.

Supplier Expectations

Suppliers and business partners are expected to:

• Comply with all applicable laws relating to modern slavery, human trafficking, and employment practices
• Not use forced, bonded, or child labour
• Ensure workers are treated fairly, paid at least the legal minimum wage, and work voluntarily
• Maintain safe and hygienic working conditions
• Flow down relevant requirements to their own suppliers where appropriat

Failure to meet these expectations may result in corrective actions, increased monitoring, or termination of the business relationship in line with QMS procedures.

Training and Awareness

We provide appropriate training to employees and relevant stakeholders to:

• Raise awareness of modern slavery risks
• Support identification of warning signs
• Ensure understanding of reporting mechanisms

Reporting Concerns (Whistleblowing)

Any individual who suspects or becomes aware of modern slavery-related activity is encouraged to report their concerns promptly. Reports may be made:

• To a line manager
• To HR or Compliance
• Via the company whistleblowing process

All reports will be treated confidentially and investigated appropriately. No individual will suffer retaliation for raising concerns in good faith.

Breach of Policy

Any breach of this policy by employees may result in disciplinary action, up to and including dismissal. Breaches by suppliers or business partners may result in contract termination.

Monitoring and Review

This policy is reviewed as part of our ISO 13485 Quality Management System Policy review process, or sooner if required due to changes in legislation, organisational size, or risk profile.