MODERN SLAVERY

Modern slavery is a criminal offence under the Modern Slavery Act 2015. It is a violation of fundamental human rights, which takes various forms, including: servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain. While the scope of the Act does not legally apply to MediCircle, the Company believe firmly in Corporate Social Responsibility, and as such are committed to acting ethically, and with integrity, in all our business relationships. This Policy has been created, not because the Company is legally obliged to do so, but because we recognise that it is the right thing to do.

MediCircle is committed to understanding modern slavery risks and to ensuring there is no modern slavery occurring within our own business. Where possible, we also aim to ensure there is no modern slavery occurring in our supply chain. MediCircle are committed to:

• Vetting the Modern Slavery Policies, where applicable, of our supply chain.

• Using labour monitoring and payroll systems to ensure all employees and sub-contractors are paid at least the minimum wage.

• Ensuring high level understanding of the risks of modern slavery by providing awareness training to relevant employees.

This Policy applies to all persons working for us, or on our behalf in any capacity, including employees, Agency Workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives, and business partners.

While we have a zero-tolerance approach to modern slavery, and we expect our supply chain to comply with our values, we acknowledge that we do not control the conduct of other individuals and organisations. However, we will not knowingly deal with any business or individual found to be involved in modern slavery. Any employee or Candidate who breaches this Policy will face disciplinary action, up to and including dismissal. Reports will also be made to relevant authorities, where required.

The Managing Director/Responsible Person is ultimately responsible for the prevention of modern slavery within our business. 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 (see Policy 52 – Whistleblowing). We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery, in whatever form, is or may be taking place in any part of our own business or in any part of our supply chain. Employees and Members are encouraged to report any concerns they may have to Management, and/or to contact the Modern Slavery Helpline on 0800 0121 700.