Modern Slavery Act Policy

The Mediworld Standards of Business Conduct

At Mediworld, we conduct our activities in a manner that respects human rights as set out in The United Nations Universal Declaration of Human Rights. We do not use any form of slave, forced, bonded, indentured or involuntary prison labour. We do not engage in human trafficking or exploitation, or import goods tainted by slavery or human trafficking. We support fundamental human rights for all people. We will not employ underage children or forced labourers. We prohibit physical punishment or abuse. We respect the right of employees to associate or not to associate with any group, as permitted by and in accordance with applicable laws and regulations.

ORGANISATION, BUSINESS AND SUPPLY CHAIN

Mediworld
Mediworld has proudly run its business in the UK since 1974, we have grown from a small business to a multinational company operating globally. We have always been committed to providing the best products at affordable prices but this has been backed by a recognition that as a global company we have responsibilities to ensure adequate protection for our own workforce and those of our suppliers.

The Mediworld Global Supply Chain
As a global business, Mediworld works with suppliers from many countries of diverse cultural, social and economic circumstances. We expect our suppliers, independent businesses, to support our expectation of fundamental rights for all people, as defined in our policies: to treat their employees with fairness, respect and dignity, and to follow practices that protect health and safety for the people working in their facilities. Just as we are committed to fair employment practices and a safe, healthful and productive work environment for our employees, we expect our suppliers to hold their own suppliers to these same standards.

SLAVERY AND HUMAN TRAFFICKING POLICIES
Mediworld is commitment to respect human rights is defined in our Standards of Business Conduct, which apply to all employees of Mediworld, and in our Supplier Code of Conduct, which applies to Mediworld suppliers globally.

The Mediworld Standards of Business Conduct
As set forth above, The Mediworld Standards of Business Conduct addresses expectations with respect to human rights, including the prohibition of human trafficking. Mediworld’s employees, managers and above, are trained annually on the Standards of Business Conduct and are required to
certify their understanding of and commitment to upholding the Standards.

The Mediworld Global Supplier Code of Conduct
Mediworld’s Supplier Code of Conduct is the cornerstone of our Supplier Workplace Accountability program and was developed through a comprehensive process that included input from suppliers, benchmarking with other corporations, and consultation with external experts and stakeholders.

The Supplier Code of Conduct applies to all suppliers in our supply chain and every supplier is required to acknowledge the Code annually. The Supplier Code of Conduct sets standards that help our suppliers understand Mediworld’s expectations, including the requirement to respect the rights
set out in the UN Universal Declaration of Human Rights, and to require that their suppliers, in turn, do the same. Slavery and human trafficking are specifically addressed in The Mediworld Supplier Code of Conduct, which states:

Suppliers shall not use any form of slave, forced, bonded, indentured, or involuntary prison labor. They shall not engage in human trafficking or exploitation, or import goods tainted by slavery or human trafficking. They shall not retain employees’ government-issued identification, passports or work permits as a condition of employment.

HUMAN RIGHTS RISK MANAGEMENT AND DUE DILIGENCE PROCESS
Mediworld has a robust risk management process in place to assess risk within our supply chain, including modern slavery. The Mediworld Supplier Workplace Accountability program provides guidance to suppliers on complying with our standards, including Mediworld expectation
that suppliers hold their supply chains to the same high standards.

Suppliers are expected to understand the expectations of the Supplier Workplace Accountability program and are required to complete a rigorous self-assessment questionnaire that appraises the supplier’s current practices and management systems. After completing the self-assessment questionnaire, suppliers receive a report indicating areas of opportunity.

Human Rights due diligence is incorporated into Mediworld’s Supplier Workplace Accountability program. Mediworld utilises third-party monitoring firms to conduct on-site announced and unannounced audits of suppliers. Examples of due diligence are a physical inspection of the facility,
including the housing and cafeterias for the workers. In addition, the monitoring firms also conduct private worker interviews and review facility records and business practices to assess compliance with the Mediworld Supplier Code of Conduct.

Modern Slavery risks are addressed specifically as part of the audit, including verifying that workers are not charged illegal fees by the supplier or a third-party employment agency. Moreover, the third-party monitoring firm reviews hiring practices to ensure workers are employed under voluntary conditions, including confirming that worker contracts are in the local language and signed by the worker, and workers have freedom of movement, including confirming
that workers have the option of retaining all personal identification documentation.

Instances of non-compliance are shared with the supplier during in an audit report. Suppliers are required to complete a corrective and preventative action plan to address non-compliance. The plan must provide specific time frames within which corrective action will be taken, root causes analysed, and policies and procedures updated. In addition, the plan must be designed to avoid recurrence of the non-compliance and establish specific accountability. In instances of significant non-compliance, suppliers are subject to a follow-up audit, the timing of which is based on the audit findings.

The Mediworld Supplier Workplace Accountability program is designed to support suppliers in meeting our standards. However, there are circumstances under which Mediworld will remove a supplier from the supply chain to address instances of significant non-compliance with The Mediworld Supplier Code of Conduct.