Modern Slavery Statement

The Modern Slavery Act 2015 (“the Act“) came into effect on October 29, 2015 and requires those entities carrying on a business or part of a business in the United Kingdom, supplying goods or services, and having an annual turnover of £36 million or more to disclose information regarding the steps they have taken to eradicate slavery and human trafficking from their supply chain as well as within their own organization during the previous financial year.

Our Company

B Medical Systems is a Luxembourg-based manufacturer and supplier of medical cold chain and temperature-controlled solutions used for the storage and transportation of vaccines, blood, biological samples and pharmaceuticals worldwide. Although B Medical Systems does not have a corporate entity established in the United Kingdom, it may supply products and services to customers in the UK as part of its international business activities.

B Medical Systems is committed to conducting its business ethically, responsibly and with integrity. We have a zero-tolerance approach to modern slavery, human trafficking, forced labour and child labour and seek to ensure that such practices do not occur within our operations or supply chains. We expect our employees, suppliers, contractors and business partners to comply with applicable laws and uphold high standards of ethical conduct and respect for human rights.

We act in respect of the principles of the Universal Declaration of Human Rights and are committed to continuously strengthening our corporate responsibility practices in alignment with the principles of the United Nations Global Compact, of which B Medical Systems is a participant.

Our commitment to human rights is set out in our Code of Conduct, which is applicable to all employees of B Medical Systems. The Code of Conduct prohibits, amongst others, any form of forced, involuntary or child labour in our operations, requires B Medical Systems to adopt sound labour and employment practices and requires B Medical Systems to treat its employees in accordance with applicable laws.

Supply Chain and Due Diligence

All B Medical Systems suppliers are expected to adhere to B Medical Systems’ ethical values and comply with the General Principles of Proper Business Conduct and Ethics for Suppliers.

As a minimum, our suppliers shall observe the following principles:

1. respect the principles defended in the Conventions of the International Labour Organization and, in particular, the abolition of child labour and the elimination of all forms of compulsory or forced labour;
2. not have recourse to illegal employment and respect current labour regulations as well as all regulations specific to its activities, including but not limited to (b.1) not practising any form of discrimination with respect to hiring or personnel management, and promoting equality in professional treatment; (b.2) not using any form of mental or physical coercion, or corporal punishment for disciplinary purposes; (b.3) prohibiting any use of forced, bonded or indentured labour or involuntary prison labour; (b.4) ensuring that any work, including overtime work, is voluntary and that workers are free to leave upon reasonable notice; (b.5) respecting current legislation with regard to working schedules, remuneration, training, collective bargaining, health and safety;
3. prevent drug and alcohol abuse by taking all reasonable steps to ensure that directors, officers, employees or contractors do not (c.1) report or endeavour to report for duty having just consumed alcohol or while under the influence of drugs; (c.2) report for duty in an unfit state due to the use of alcohol or drugs; (c.3) possess drugs of abuse in the workplace; (c.4) consume alcohol or drugs whilst on duty;
4. work against corruption by forbidding the offer or payment of bribes to its customers or to the business associates of its customers and by forbidding its employees to request or accept bribes, whether for their own benefit or that of their families, friends, associates or acquaintances;
5. support and respect the protection of internationally proclaimed human rights and ensure they are not complicit in human rights abuses;
6. adhere to the principles of environmental protection by (f.1) supporting and respecting the fundamental principles of environmental protection through the implementation of an environmental policy aimed at alignment with the best practices in the profession; (f.2) ensuring scrupulous respect of mandatory local, national and international regulations in effect as well as general environmental protection principles in the framework of its activities; (f.3) controlling the impact of its activities on the environment by adopting measures to identify the environmental consequences of these activities; (f.4) promoting the environmental principles set forth above in its dealings with its own suppliers, service providers and/or sub-contractors; and
7. ensure that parts and products supplied to B Medical Systems are DRC conflict-free (do not contain metals derived from “conflict minerals”: columbite-tantalite (tantalum), cassiterite (tin), gold, wolframite (tungsten), or their derivatives) such that they do not directly or indirectly finance or benefit armed groups through mining or mineral trading in the Democratic Republic of the Congo or an adjoining country. Suppliers are to establish policies, due diligence frameworks and management systems, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, that are designed to accomplish this goal.

Effectiveness

B Medical Systems applies a risk-based approach to supplier and third-party management. Prior to engagement, suppliers are subject to qualification procedures. Supplier assessments are performed on a risk-based basis, taking into account factors such as the nature of the goods or services provided and other relevant risk indicators. Where concerns are identified, appropriate corrective actions may be implemented.

B Medical Systems may carry out audits and, where issues are identified, it works with the supplier to ensure improvements are made. These audits may include interviews with workers and the management, inspections of production sites and document reviews. Audit findings or non-conformances are prioritized based on risk. Should a critical issue be identified, B Medical Systems would require a timely response from the supplier, and if a supplier failed to adequately remediate the issue, the relationship would be re-evaluated and, if necessary, terminated.

To further improve the efficiency of our compliance management system, B Medical Systems operates a whistleblowing platform that allows employees to raise various concerns, including concerns about how colleagues are being treated, practices within the business or supply chain, or any observed or suspected violations of the law or of B Medical Systems’ policies. Such reports are wholly confidential, and any employee who makes a report in good faith will be protected from retaliation.

Training

Mandatory awareness and training regarding applicable legal rules and the policies in force at B Medical Systems are in place.

Next Steps

Over the course of the next financial year, we will continue to enhance our procedures to help us identify, prevent and mitigate risks of modern slavery or human trafficking. Below are some examples of how we intend to deliver this:

Supply chain: we will work internally and externally with our suppliers to improve supply chain standards.

This statement has been approved by the CEO of B Medical Systems S.à r.l.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes B Medical Systems’ slavery and human trafficking statement for the previous financial year (FY25).

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