Modern Slavery & Human Trafficking Policy

Purpose: As an ethical organisation, this policy serves to demonstrate our commitment to a zero-tolerance approach to all forms of modern slavery and human trafficking.

1. Policy Statement
Modern Slavery and human trafficking is a crime and a violation of human rights Under the Modern Slavery Act 2015. It is deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain and will not be tolerated in any way by our company. Eureka Physiocare is committed to act with integrity and ethically in every business relationship and transaction. Controls are in place to ensure modern slavery or human trafficking does not take place anywhere in the supply chain or business.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all our contractors, suppliers and other business partners. As part of our supplier engagement processes, we prohibit the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee’s contract of employment and we may amend it at any time.

2. Responsibility for the Policy
The Procurement Department has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it The Purchasing Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training. | 01686 625 752 | [email protected] Eureka Physiocare LTD| Unit F, Mochdre Ent Park, Newtown, SY16 4LE, UK | Company number 13730060 Doc 306-Issue 09 05 2022-DM

3. Due Diligence Processes
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers, making clear our expectations of business partners, evaluating the modern slavery and human trafficking risks of each new supplier, and invoking sanctions against suppliers that fail to improve their performance. To ensure all those within our supply chain and contractors comply with our values, we have in place a standard clause in our supplier approval form informs them of our commitment to combatting slavery and human trafficking and requires them to agree to this commitment when working with us. We are committed as a company to tackling modern slavery and human trafficking and want to work with suppliers who share this commitment

4. Compliance with this Policy
Suppliers must ensure that they read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager OR the Procurement Department as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager immediately. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.

5. Training and Awareness
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and our supply chains, we intend to develop a training and information campaign to help staff to better understand the risks and how we as an organisation are working to manage this. All our staff have been provided with a copy of this policy, which encourages individuals to monitor and report anything untoward. We would also encourage our business partners to provide training to their staff and suppliers. | 01686 625 752 | [email protected] Eureka Physiocare LTD| Unit F, Mochdre Ent Park, Newtown, SY16 4LE, UK | Company number 13730060 Doc 306-Issue 09 05 2022-DM

6. Breaches of this Policy
Any employee who breaches this policy will face disciplinary action which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

7. Further Steps
Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking: Continuous monitoring of our business and its supply chains to ensure we are free from slavery and human trafficking with a particular focus on areas of the supply chain that are deemed the highest risk. continuing to require our contractors and supply chains to act in accordance with our Anti-Slavery policy when dealing with us; and ongoing education and promotion of our Anti-Slavery Policy along with a training program to ensure our staff understand and adopt our values. This policy is made pursuant to section 54(1) of the Modern Slavery Act 2015

8. Monitoring
This policy will be monitored by the Director; this will include the review of legal obligations, as well as making this policy available to all interested parties.

Reviewed 26/10/2023

Responsible Person: Mr Danny Morren, Director

Emergency Helpline: 01686 625752