Human Trafficking and Slavery Statement

For the Financial Year Ended 31 December 2025
Issued pursuant to Section 54, Part 6 of the Modern Slavery Act 2015

1. Introduction

This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 (the “Act”) and sets out the steps taken by UK Vein Clinic Ltd and its subsidiaries (together “the Company”) to prevent modern slavery and human trafficking in its business operations and supply chains for the financial year ending 31st December 2025.

‍UK Vein Clinic Ltd is committed to conducting its business ethically and with integrity, ensuring that slavery, servitude, forced or compulsory labour, and human trafficking play no part in any aspect of our business or supply chain.

2. Organisational Structure and Business

UK Vein Clinic Ltd is a private limited company, operating in the Healthcare industry. We have 150 employees and operate in 14 locations.
Our principal activities include the provision of diagnostic appointments and treatment for patients with venous disease.

We operate both privately and within the NHS. Our supply chains include suppliers of medical equipment, contractors and logistics providers.

This statement covers the activities of all entities wholly owned or controlled by UK Vein Clinic Ltd.

3. Policies Relating to Slavery and Human Trafficking

We are committed to upholding the highest standards of ethical conduct. Our policies reflect our zero-tolerance approach to slavery and human trafficking and include:

• Modern Slavery and Human Trafficking Policy – outlining our stance and expectations for staff and suppliers.
• Code of Conduct– requiring compliance with human rights, labour laws, and ethical standards.
• Whistleblowing Policy – enabling employees and third parties to report any concerns about unethical or illegal practices confidentially.
• Supplier Code of Conduct – requiring all suppliers to commit to ethical labour practices, including compliance with the Modern Slavery Act 2015.

4. Due Diligence Processes

We undertake due diligence to identify and mitigate risks related to slavery and human trafficking within our supply chains. This includes:

• Conducting risk assessments of new and existing suppliers.
• Requiring suppliers to confirm adherence to our Supplier Code of Conduct.
• Reviewing supplier audits and compliance certifications where applicable.
• Engaging only with reputable recruitment agencies that adhere to labour laws and ethical standards.

In addition, the Company undertakes employment checks for all directly employed staff, including verification of identity, right to work in the United Kingdom, professional registration (where applicable), and references. These checks help ensure that all workers are employed voluntarily and in accordance with applicable employment legislation.
‍
Where appropriate, contractual provisions are included within supplier agreements requiring compliance with the Modern Slavery Act 2015 and permitting the Company to investigate concerns relating to labour standards and ethical conduct.

5. Risk Assessment and Management

We recognise that the greatest risk of modern slavery and human trafficking may exist in our extended global supply chain, particularly in manufacturing, or low-wage labour markets.
‍
To address this, we:

• Identify high-risk suppliers and sectors based on country of operation and type of labour used.
• Prioritise audits and engagement with high-risk suppliers.
• Terminate relationships with suppliers that fail to meet our ethical standards after reasonable remediation efforts.

The Company recognises that healthcare staffing and recruitment supply chains may present specific risks where temporary workers, agency staff or subcontracted services are utilised. To mitigate these risks, the Company works only with reputable suppliers and recruitment agencies that can demonstrate compliance with relevant employment legislation, workforce governance requirements and ethical recruitment practices.
‍
Risk assessments are reviewed periodically and whenever there is a significant change to operations, suppliers or service delivery arrangements.

6. Training and Awareness

We provide training to all relevant staff to ensure they understand the risks of modern slavery and human trafficking, how to recognise warning signs, and how to report concerns.
‍
Training covers:

• The principles of the Modern Slavery Act 2015.
• Identifying indicators of forced labour or trafficking.
• Procedures for reporting and responding to suspected cases.

7. Effectiveness and Performance Indicators

To monitor the effectiveness of our measures, UK Vein Clinic Ltd tracks key performance indicators, including:

• Number of suppliers reviewed and audited for modern slavery risks.
• Number of employees trained in modern slavery awareness.
• Reports or concerns raised and resolved.
• Corrective actions implemented with suppliers.

The Company also measures effectiveness through:

• Completion rates for modern slavery awareness training.
• Percentage of suppliers assessed for modern slavery risk during onboarding.
• Number of supplier compliance concerns identified and resolved.
• Confirmation that all employees have undergone appropriate right-to-work checks.

Performance is reviewed annually by senior management as part of the organisation's governance and compliance framework.

8. Continuous Improvement

We recognise that eradicating modern slavery is an ongoing challenge. We are committed to continual improvement by:

• Strengthening supplier engagement and auditing processes.
• Reviewing and updating our policies annually.
• Collaborating with industry partners, NGOs, and government bodies to share best practices.

9. Approval and Signature

This statement has been approved by the Board of Directors of UK Vein Clinic on 19 February 2025. It will be reviewed and updated annually.
‍
Signed for and on behalf of UK Vein Clinic Ltd

Peter Finigan
Dr Peter Finigan – Medical Director