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Policy

Modern Slavery and Human Trafficking Statement

Our commitment to preventing modern slavery in our operations and supply chain

Policy owner
Reece Stevenson, Chief Executive Officer
Version
v1.0
Effective date
9 September 2026
Next review
September 2027
Approved by
The Board of Directors, Vitalex Ltd

1. Our commitment

Vitalex has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity, and to taking reasonable and proportionate steps to ensure that slavery, servitude, forced or compulsory labour and human trafficking are not taking place in our business or in our supply chains.

2. Our business and our supply chain

Vitalex Ltd is a UK distributor of single-use surgical procedure packs, sterile draping sets and gowns, supplying healthcare, dental and veterinary providers. We do not manufacture.

Our supply chain consists principally of established medical-device manufacturers operating under certified quality systems including ISO 13485, together with logistics, waste-recovery and professional service providers. Our current manufacturing partners are based in Portugal, the United Kingdom and Turkey.

We consider the risk of modern slavery within our direct, regulated manufacturing partners to be low. We recognise that risk can exist deeper in any global supply chain, particularly in raw material production and in agency or contract labour, and that a low assessed risk is not the same as no risk.

3. Our policies

This statement is supported by our Ethical Trading Policy, our Whistleblowing Policy, which allows concerns to be raised in confidence and without detriment, our Anti-Bribery and Corruption Policy, and our Terms and Conditions of Purchase, which require suppliers to comply with modern-slavery law and to cascade equivalent standards to their own suppliers.

4. Due diligence and risk

As part of onboarding and managing suppliers we:

  • ▪ work with established manufacturers holding recognised certifications, and verify those certifications rather than accepting them on assertion;
  • ▪ include ethical and modern-slavery expectations in our purchasing terms, giving them contractual force;
  • ▪ reserve the right to seek information or audit where a risk is identified; and
  • ▪ will end a relationship where a serious concern is not addressed.

5. Training and awareness

Those involved in purchasing and supplier management understand the risks of modern slavery in medical-device supply chains and know how to raise a concern. As the business grows we will formalise this into recorded training.

6. Effectiveness

Vitalex is an early-stage business and we are candid that we do not yet have years of data against which to measure effectiveness. In this first period our measures are simple and factual: the proportion of active suppliers who have accepted our purchasing terms, the number of supplier due-diligence assessments completed, and the number of modern-slavery concerns raised and how each was resolved. We will report against these in future statements.

7. Approval

This statement is made in respect of the current financial year. It has been approved by the Board of Directors of Vitalex Ltd and will be reviewed and, where appropriate, updated annually.

Signed by Reece Stevenson, Chief Executive Officer, for and on behalf of Vitalex Ltd, on 9 September 2026.