Modern Slavery Policy

This slavery and human trafficking statement is made pursuant to s.54 of the Modern Slavery Act 2015 for the period from 1 April 2019 to 31 March 2020. It sets out the steps that Tillomed Laboratories Limited (“we”) has taken and is in the process of implementing to prevent slavery and human trafficking in its own business and in its supply chain.

We are committed to conducting business ethically and with integrity, respecting the rights of individuals and respecting the environment. We expect our staff and the suppliers who do business with us to share the same commitments and work to the same high standards.

We are committed to respecting the human rights of our employees in the workplace. We have a zero-tolerance approach to slavery and human trafficking and we act ethically in all of our business dealings and relationships.

We are confident that slavery and human trafficking does not take place in any part of our own business. As an employer we are committed to providing a fair salary and good conditions of employment, providing a healthy and safe working environment, promoting the development and dignity of individual employees; and are opposed to discrimination at work.

Company overview – our business and structure

We are a wholly owned subsidiary of Emcure Pharma UK Ltd. Our principal business is the supply of pharmaceutical products predominantly to wholesalers in the UK and Europe.

We are licensed and regulated by the Home Office and the Medicines and Healthcare Products Regulatory Agency (MHRA) in the UK.

Our supply chain

We purchase medicines and other goods and services from third party suppliers worldwide and strive to conduct business with third party suppliers who share our commitment to high ethical standards and who operate in a responsible and ethical manner towards their workers
and suppliers. Our suppliers are principally from India and Europe.

We choose our suppliers with care. Acknowledging the importance of the Modern Slavery Act in the context of our supply chain, we will enhance our due diligence as relevant to modern slavery and human trafficking, taking a proportionate approach commensurate to the prevailing risks. We acknowledge the elevated risk of modern slavery in certain countries of
the world, including India, and will develop our due diligence and evaluation processes to address those elevated risks appropriately.

The development of a programme to seek to assure ourselves that our supply chain is and remains free of modern slavery and human trafficking

We are notifying all our direct suppliers of our expectations in relation to the prohibition in relation to modern slavery by way of introducing an anti-slavery and anti-human trafficking compliance clause in new contracts and contract renewals with third party suppliers.

Monitoring and enforcement

We accept that effective action to prevent modern slavery and human trafficking in our business and supply chain requires monitoring.

Our management takes and will continue to take a zero-tolerance approach to modern slavery and human trafficking and will react accordingly to any identified transgression whether by our staff or by our suppliers.

The development of our policies and staff training

As a part of our plan to formalise expected working attitudes and the adherence to high ethical standards, we are developing both a Supplier Code of Conduct and a Corporate Social Responsibility policy each of which will include provisions relevant to modern slavery and human trafficking.

The development of the above policies will form part of our staff training programme which will reinforce our expected standards of conduct.

A progressive approach to compliance

We recognise that the risks from modern slavery and human trafficking change. We also recognise that efficient methods to identify and address modern slavery and human trafficking will be developed and enhanced. We will monitor and evaluate such developments and our approach to preventing modern slavery will be reviewed annually so we can adapt and
improve our approach.

This statement was approved by the Board of Directors of Tillomed Laboratories Limited, and signed on its behalf, on 15 October 2019.