Modern slavery

ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE YEAR 2023 (“STATEMENT”)

ABOUT THIS STATEMENT
This statement has been published in accordance with the Modern Slavery Act 2015 (‘MSA’), which requires Sinclair Pharma Limited and Sinclair Pharmaceuticals Limited to set out the steps taken by them and the other companies in Sinclair Pharma Limited’s group (together ‘Sinclair’) during the calendar year ending 31 December 2023, and the steps that Sinclair will continue to take, to prevent modern slavery and human trafficking within our business and supply chains.

MODERN SLAVERY
This statement explains Sinclair’s stance and actions relating to modern slavery and how we accept our responsibility to respect and protect the human rights of all those who encounter our business operations. For simplicity, we use the expression ‘modern slavery’ to encompass all forms of slavery, servitude, forced and compulsory labour, child labour and human trafficked labour.

OUR BUSINESS
As a leading aesthetic company, Sinclair plays a significant and active role in driving aesthetic advancement, whilst offering an innovative portfolio of products to patients, physicians, and clinics. Sinclair conducts all activities within a highly regulated, ethical framework and is committed to meeting high ethical standards whilst ensuring compliance with all applicable local and international laws, wherever we conduct our business. It is essential to create and maintain a healthy and ethical environment for all, and our internal processes ensure that this business conduct is filtered throughout all commercial operations.

STRUCTURE AND SUPPLY CHAINS
Our product suppliers (‘suppliers’) are chosen on the basis of quality, cost, location, compliance to regulatory standards, compliance to our own policies and standards, and integrity.
Sinclair has a global supply chain network, and a number of our suppliers are issued with an annual Modern Slavery Questionnaire, which they must complete and return to Sinclair, detailing their practices and procedures to combat Modern Slavery.
POLICIES ON MODERN SLAVERY
Sinclair operates various internal policies (“policies”) including the below highlighted policies for identifying and preventing slavery and human trafficking in our operations:

• Speak Up Policy- we encourage all employees to report any suspicion of slavery or human trafficking without fear of retaliation. Reports can be made anonymously and be kept confidential to the extent permitted by local law.
• Code of Ethics- our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

We are in the process of introducing a Partner Code of Conduct which all of our suppliers will be required to follow to continue to raise awareness of the ethical standards that Sinclair expects.
These policies are reviewed annually and require employees, officers, consultants, contractors, casual workers, and agency workers to respect human rights and act with integrity. Together, these policies set Sinclair’s standards and expectations to help mitigate against any form of modern slavery and human trafficking.

DUE DILIGENCE AND AUDITS PROCESS
Sinclair understands that the biggest risk of exposure to modern slavery is in the product supply chain services that we purchase from third parties. Within these channels, new suppliers and factories/sites are subject to stringent due diligence including audits of suppliers considered to have a medium to high-risk impact on product quality. We evaluate our suppliers through risk-based assessments and expect them to be compliant with our own high-quality standards, including a strict requirement of no form of modern slavery. In addition, we have carried out reviews of the Modern Slavery Questionnaires that have been completed by a number of our suppliers, with the intention of assessing and identifying any modern slavery practices. In the event any issues are identified, appropriate remedial action will be taken.

ASSESSMENT OF MODERN SLAVERY RISK
We are aware that certain industries/sectors and geographical areas pose different levels of risk in relation to modern slavery. Where through carrying out a risk assessment we have identified that suppliers operate in a potentially higher risk area we intend to incorporate processes in the next fiscal year whereby we will review:

• The suppliers’ policies and/or position relating to modern slavery including the controls they implement to eliminate the risk of modern slavery and human trafficking; and
• The whistleblowing processes in place for suspicions to be raised concerning modern slavery practice.

SUPPLIER AGREEMENTS
Sinclair’s agreements with its suppliers require them to always comply with local and international laws and allow for termination in the event that they fail to do so.

MODERN SLAVERY AWARENESS
We believe in acting with integrity and demonstrating utmost respect for people, which resonate with helping to prohibit modern slavery and we expect all of our employees, officers, consultants and contractors to respect these values.
To continue to raise awareness of the ethical standards that Sinclair expects a communication will be sent to all suppliers reminding them of Sinclair’s zero-tolerance approach to modern slavery and the standards that we expect.
We will also send an internal communication across the business to reiterate our commitment in the fight against modern slavery including red flags to look out for that may indicate slavery or human trafficking and reminding employees how they should report any concerns.
TRAINING
Sinclair intends to roll out an internal global training programme which will be tailored appropriately depending on the role of the department and will include:

• Explaining the various forms of modern slavery in which people can be held and exploited.
• How employees can identify the signs of slavery and human trafficking.
• How employees should respond if they suspect slavery or human trafficking.
• What external help is available for the victims of slavery.
• What terms and guidance should be provided to suppliers in relation to slavery policies and controls.

What steps Sinclair will take if a supplier fails to implement anti-slavery policies or controls.

MEASURING EFFECTIVENESS
Sinclair measures its effectiveness in compliance with the MSA, through its ongoing audits, assessments, and training and through the policies it issues, all of which are reviewed on a regular basis. We will continue to update our policies to raise awareness and look at how we can further address the potential issue of modern slavery within our business and supply chain.
Our maintenance of the appropriate safeguards against any mistreatment of persons working for or in connection with our business will continue, as we uphold the key value of acting with integrity.
We will review the effectiveness of our approach on an annual basis and report our progress in future statements. We will be specifically looking at:

a) Mandatory training completion figures.
b) Responsiveness to the Modern Slavery questionnaire.
c) How many suppliers have an awareness and training programme related to Modern Slavery.
d) Whistleblowing reports that have been made that show employees have an awareness and sensitivity to ethical issues.

This statement has been approved by Sinclair’s Board of Directors
Signed:

Miguel Pardos
Sinclair’s Chief Executive Officer
Dated: 22nd December 2023