This Statement is made pursuant to section 54 of the Act and constitutes the Modern Slavery and Human Trafficking Statement for the Financial Year ended 31st December 2025 for Mundipharma International Ltd (the “Company”)
Overview
The Company is a member of a global network of independent associated companies (Mundipharma). The Company provides business services to related party clients within the pharmaceutical sector.
Following the introduction of the Modern Slavery Act 2015 (subsequently amended by the Modern Slavery (Amendment) Bill 2021) (the “Act”), we analyze the risks within our own business and our supply network annually based upon the industry in which we operate and the geographical locations in which we conduct business. Having analyzed the risks within our business and supply network, we are not currently aware of any areas in our operations, which are likely to lead to a breach of human rights and the Act. We do not believe that the risk within our business and our supply network for the period 1 January to 31 December 2025 has changed since our Statement for the financial year ended 31 December 2024. We remain committed and it is our policy to never knowingly deal with any organization connected to any kind of slavery or human trafficking or child exploitation.
Our business is committed to operating in an ethical and transparent manner. In line with this commitment, the Company has incorporated into its Code of Conduct the requirements of the Act. We take the upholding of these high standards seriously and do not tolerate slavery or human trafficking within our organization or from those whom we acquire products or services. We have implemented a Code of Conduct for Third Parties that sets out our expectations of our third-party partners across multiple areas including health and safety, human rights (modern slavery, human trafficking or child labour) and sustainability. Human rights concerns (and any form of forced labour, child labour, slavery, or human trafficking) are specifically mentioned in our Third-Party Code of Conduct as practices that we require our suppliers to prohibit. The incorporation of modern slavery clauses within our supply agreements is ongoing. Further, our procurement agreements do incorporate the Code of Conduct for Third Parties.
The Mundipharma Environmental, Social & Governance (“ESG”) Steering Group (the primary purpose being to oversee, identify principal risks and implement appropriate measures to effectively monitor, manage and drive patient centricity and sustainable operations within the Mundipharma business) issued the ESG Statement of Intent during 2025 confirming the Company’s and Mundipharma’s ongoing commitment to governance and ethical practice as well as social responsibility and is available here: https://www.mundipharma.com/acting-integrity
Mundipharma is in the process of implementing its “Mundipharma Modern Slavery Policy” which will further enhance the Company’s modern slavery measures and controls currently in place. The “Mundipharma Modern Slavery Policy” will lay the groundwork and provide the foundation for the implementation of the risk assessment tools and measures to further monitor the effectiveness of the Company’s modern slavery controls (details of the “Mundipharma Modern Slavery Policy” will be included in the Mundipharma ESG Statement of Intent to be issued during 2026).
Policies, contract clauses, training, communication and the raising of concerns
The Board of Directors, senior management and senior leaders, including the supply chain and procurement functions are aware of the modern slavery obligations contained within the Act. The Company recognizes that a key component of managing and mitigating modern slavery risks in its operations and supply chain is the ongoing raising of awareness of modern slavery and the ensuring of ethical and fair practices within the business operations. As a consequence of the Mundipharma policies currently in place within the business (which include amongst others the Code of Conduct and the Anti-Bribery and Anti-Corruption Policy as well as the Speak Up guidance), the Company has an environment and a culture which encourages open and frank two-way communication, and employees are encouraged and expected to raise concern about any known or suspected violation of the Code of Conduct or other illegal or unethical business conduct. The Code of Conduct and Anti-Bribery and Anti-Corruption Policy provide a foundation for acting with integrity for all employees. Therefore, the current business culture encourages reporting of misconduct including the reporting of ethical concerns. Any such concern can be raised in confidence without fear of retaliation by approaching Management, HR, Legal or Compliance. Alternatively, individuals may report their concerns, and if desired remain anonymous, through our on-line reporting hotline integrityline.mundipharma.com which is available 24 hours a day. The Company and Mundipharma do not tolerate any form of bullying, discrimination or harassment as outlined in the Preventing Harassment in the Workplace Policy and our Equal Employment Opportunity Policy. Any concerns raised will be reviewed and, if required, investigated to determine appropriate action(s) where required. We aim on an ongoing basis to continue to equip those employees involved in procurement activities, with both the knowledge and understanding of the importance of the Act and the roles that employees play in helping to eradicate modern slavery, trafficking, and child exploitation.
Employment Practices
Our employment practices are compliant with applicable employment and health and safety legislation, and as a result, we are confident that there is no slavery or human trafficking taking place within our organization. Furthermore, we ensure that the employment agencies that we deal with are fully compliant with the Act and applicable legislation (having enshrined within their policies and process mechanisms for the identification of the risks associated with modern slavery, including such practices leading to the introduction of various laws within the employment field).
Due Diligence
We aim to continually improve transparency within our business and the supply chain and not to work with any supplier that we suspect is connected in any way with slavery or human trafficking. The due diligence process involves assessing the third party, where appropriate, through completion of a questionnaire, business justification review and background checks (including screening against watchlists and adverse media) of third-party organizations. Our third-party business partners are subject to Mundipharma’s Third Party Risk Management process, which assesses a broader range of risks including areas such as ethics and compliance, anti-bribery and corruption and fraud. Mundipharma’s ESG department also assesses third party suppliers’ activities in relation to supply chain emissions and supply chain related risks through the issuing of questionnaires, which include questions around the supplier’s modern slavery policies and procedures. Therefore, as part of our Compliance Programme, steps are continually being taken to carry out the required due diligence and on-boarding process to assure ourselves that we only partner with reputable third parties carrying out their business practices in a fit and proper manner and in full compliance with the requirements of the Act.
Monitoring and Enforcement
We will continue to raise awareness and to monitor third-party supplier and partner relationships and continue to mitigate the risk of modern slavery. We acknowledge that there is more to be done in relation to preventing modern slavery and remain committed to continually enhancing the Modern Slavery framework in future years.
Any suspected breach of our Compliance Programme or of our Third-Party Code of Conduct, including the Act, will be investigated and such investigations could lead to the termination of supplier contracts and other actions being taken, as may be appropriate.
Conclusion
During 2025 no modern slavery, human trafficking or child exploitation incidents were reported or identified by the Company within the business or the businesses of its suppliers, customers or service providers. The Company will continue to apply appropriate risk-based due diligence processes to raise awareness and to monitor supplier relationships in order to mitigate the risk of modern slavery.
This Statement (made by the Company pursuant to section 54 of the Act and constitutes the Modern Slavery and Human Trafficking Statement for the Financial Year ended 31 December 2025, covering the period 1 January to 31 December 2025) was reviewed and approved by the Board of Mundipharma International Limited on 29 June 2026.
Bryan Lea, Director