PharmaEthical

1. Introduction

PharmaEthical Ltd ('PharmaEthical', 'we', 'us', 'our') is committed to acting ethically, with integrity, and with transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery or human trafficking within the business and its supply chain.

This statement is made on behalf of PharmaEthical Ltd pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 31 March 2025.

2. Our Organisation Structure and Business

PharmaEthical is a UK-based healthcare solutions company founded by Dr Mayuragoban Balasubramaniam, a qualified NHS doctor. The company designs and develops innovative health technology solutions to improve clinical governance and deliver high-quality healthcare services to local communities. PharmaEthical operates through its wholly owned subsidiary, Amal Pharmacy, leveraging technology to serve community pharmacies, nursing homes, residential care homes, and other healthcare settings.

Our key activities include:

• Design and development of health technology platforms for community pharmacies and care settings.
• Provision of accurate and on-time medicine delivery and dispensing services.
• Consultancy and clinical governance solutions for healthcare providers.
• Operation of Amal Pharmacy as a direct patient-facing service.

3. Our Supply Chains

PharmaEthical's supply chains are primarily UK-based, reflecting the nature of our business as a healthcare technology and pharmacy services provider. Our principal supply chain categories include:

• Pharmaceutical wholesalers and licensed medicine distributors regulated by the MHRA.
• Medical device and consumables suppliers operating under UK and EU regulatory frameworks.
• IT hardware, software, and infrastructure providers.
• Professional services providers, including legal, accountancy, and HR consultants.
• Facilities management and building maintenance contractors.

Given the regulated nature of the pharmaceutical sector, the majority of our suppliers are subject to extensive government oversight, which reduces, but does not eliminate, the risk of modern slavery practices within these supply chains.

4. Our Policies in Relation to Modern Slavery

PharmaEthical maintains internal policies that reflect our commitment to acting ethically and with integrity across all business operations. The following policies are particularly relevant to our approach to modern slavery:

4.1 Supplier Code of Conduct

We require all suppliers and business partners to comply with our Supplier Code of Conduct, which sets out our expectations regarding fair labour practices, prohibition of forced or compulsory labour, child labour, and human trafficking. Non-compliance may result in termination of the commercial relationship.

4.2 Recruitment and Employment Policy

All employees are engaged directly through transparent employment contracts. PharmaEthical uses only reputable, vetted recruitment agencies where required and verifies the right to work for all employees in accordance with UK immigration law. We do not charge recruitment fees to prospective employees.

4.3 Whistleblowing Policy

We encourage and empower all staff to speak up about any concerns relating to modern slavery or unethical conduct without fear of retaliation. Our whistleblowing policy sets out clear, confidential channels for raising concerns, including reports directly to senior management and, where appropriate, to external authorities.

5. Due Diligence Processes

To identify and mitigate the risk of modern slavery in our operations and supply chain, PharmaEthical undertakes the following due diligence activities:

• Pre-engagement screening of new suppliers, including review of publicly available information and, where material, completion of a supplier questionnaire.
• Verification that pharmaceutical suppliers hold valid MHRA wholesale dealer licences and comply with Good Distribution Practice (GDP) guidelines.
• Review of supplier modern slavery statements (where applicable) as part of our procurement process.
• Internal review of employment records, payroll practices, and agency worker arrangements.
• Annual management review of supply chain risk.

6. Risk Assessment

We have assessed the risk of modern slavery across our operations and supply chain. Key findings are summarised below:

7. Training and Awareness

PharmaEthical is committed to ensuring that all staff understand the risks of modern slavery and human trafficking. Our approach to training and awareness includes:

• Induction training for all new employees covering modern slavery awareness, our Supplier Code of Conduct, and our whistleblowing policy.
• Targeted training for staff in procurement, HR, and management roles who are most likely to encounter modern slavery risks.
• Periodic communications to all staff to maintain awareness and communicate any policy updates.
• Access to Government guidance and the Modern Slavery Helpline (0800 0121 700) is made available to all employees.

8. Key Performance Indicators

To measure the effectiveness of the steps we are taking to ensure modern slavery is not taking place in our business or supply chains, we track the following indicators:

• Number of employees who have completed modern slavery awareness training.
• Number of supplier due-diligence questionnaires issued and returned.
• Number of whistleblowing disclosures received and investigated.
• Number of suppliers reviewed against our Supplier Code of Conduct annually.
• Any incidents of suspected modern slavery identified, investigated, and reported.

9. Our Commitments for the Year Ahead

PharmaEthical is committed to continuously improving our approach to tackling modern slavery. In the coming year, we intend to:

• Formalise and document our Supplier Code of Conduct and distribute it to all existing and new suppliers.
• Develop and roll out a structured modern slavery e-learning module for all employees.
• Introduce a formal modern slavery risk register to be reviewed at board level annually.
• Engage with industry bodies and NHS supply chain partners to share best practice.
• Review and update this Statement annually and publish it on our website.

10. Approval and Sign-off

This statement has been approved by the Board of Directors of PharmaEthical Ltd and is signed by the founding director.

Dr Mayuragoban Balasubramaniam

Director and Founder, PharmaEthical Ltd

Date: 03/06/26

This statement is published on the PharmaEthical website at www.pharmaethical.com and will be reviewed and updated annually in accordance with Section 54 of the Modern Slavery Act 2015.

Healthcare Technology | Amal Pharmacy | www.pharmaethical.com