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Intended for UK patients and members of the public

Modern Slavery Statement

Modern Slavery Act Statement - 2025

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 by Accord Healthcare Ltd and Accord-UK Ltd (collectively, “Accord” or “we”).

Our Board of Directors and senior leadership are committed to preventing slavery and human trafficking in our corporate activities and supply chains.

This statement sets out actions taken by Accord to understand and mitigate potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking either in our own business or in our supply chain.

Accord ’s modern slavery statement is based on the definitions set out in the Modern Slavery Act 2015 and is guided by the UN Universal Declaration of Human Rights and the conventions of the International Labour Organisation particularly relating to forced or compulsory labour.

Our Business

Accord’s business is the development, manufacture and sale of medicinal products to hospitals, community pharmacies, clinical groups, wholesalers and (whenever allowed) to dispensing doctors across mainly in the UK, Europe, and Middle East and North Africa (“EMENA”) and in the rest of the world.

Robust processes are put into place to identify and mitigate areas of risk including modern slavery and human trafficking.

Our Policies

In our Code of Conduct for Business Partners, Accord takes a zero-tolerance approach to child labour and young workers, forced labour and modern slavery. Business partners should commit to adhering to the requirements, principles and standards set out in our Code of Conduct for Business Partners.

If any business partner is found to be in breach of the principles of the Code of Conduct for  Business Partners, cannot adhere to it in its entirety, or conducts business in a manner that conflicts with our policies, Accord will make use of all or any of its rights, including its right to review the business relationship with the business partner and take appropriate action such as the termination of the contractual relationship.

Our Supply Chain

Accord purchases medicines, pharmaceutical ingredients and components from third party suppliers. Accord’s goal is to work with suppliers who embrace and comply with all applicable laws and our principles, and, in turn, have these suppliers encourage compliance from any suppliers with whom they work.

Due Diligence

Our primary due diligence tool is our risk-based 'Know Your Business Partner' (“KYBP”) process. This is performed before onboarding new suppliers in scope of our KYBP policy and is refreshed periodically (every 1-3 years) based on the supplier's risk profile. The KYBP process includes an assessment of the supplier’s modern slavery position (during onboarding), where they are legally required to publish one, a review of publicly available news related to legal and ethical practices/violations and a questionnaire requesting more detailed information about the supplier’s operations and key employees.

Accord’s Internal Audit team conducts periodic reviews of key suppliers to assess compliance with the contractual obligations and adherence to Accord’s standards.

Accord is able to offer training support for partners without established compliance frameworks in place.

Training

Accord has invested in raising the awareness for modern slavery and the importance of compliance by providing a specialised training for leaders and managers during its annual compliance day.

Assessment of modern slavery risk

Accord’s belief is that the risk of modern slavery in our directly employed workforce is low due to the highly regulated nature of our industry. We recognise that our exposure to the risk of modern slavery increases when we engage with third parties in certain sectors and countries.

Continuous Improvement

Accord has initiated the certification process to the Business Partner Code of Conduct defining the standards by which all suppliers should be working. Accord aims at completing the certification process for all medicinal suppliers by March 2026. Accord will continue to provide regular training relating to modern slavery and other relevant topics.

Further steps

Accord will continue to review and improve its practices to identify and eliminate potential modern slavery or human trafficking from our business, which includes further development of our Third-Party Risk Management Framework. Accord’s senior leadership will continue governing the implementation of mechanisms for continuous monitoring and improvement of the adherence to the modern slavery legislation and best practice.

Reporting and investigating concerns

Accord employees, business partners and other third parties may raise compliance concerns including those related to modern slavery. All reports will be taken seriously and managed sensitively via a dedicated, supportive and impartial process. Any concerns should be raised either with the respective Accord main contact or via the Speak Up hotline.

Accord investigates all reports of possible misconduct and any unethical, illegal or inappropriate activity. For the financial year ended 31st March 2025 no reports have been received in relation to modern slavery or human trafficking.

Approval process

This statement has been prepared in accordance with the requirements of Section 54 of the Modern Slavery Act 2015. It has been reviewed and approved by the Board of Directors of Accord Healthcare Ltd and Accord-UK Ltd.

Signed,

Stephen Ford

Director - Accord Healthcare Ltd

Signed,

Jamie Sparrow

Director - Accord-UK Ltd

Date of Statement: September 2025

Our next statement will follow the year ending 31st March 2026.

Recent Date of Preparation: September 2025

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