Anti-Slavery and Human Trafficking Policy

Introduction

Skyrocket Phytopharma is the UK Responsible Person and distributor for the Neuropad® 10-Minute Screening Test and Neuropad® Foot Repair Foam.

Skyrocket Phytopharma is committed to preventing slavery and human trafficking in all its business activities and supply chains. This policy is in accordance with the Modern Slavery Act 2015, and reflects our zero-tolerance approach to modern slavery and human trafficking.

Organisational Structure and Supply Chains

The Company operates primarily within medical device production and distribution in Europe and North America, with a supply chain that includes suppliers, contractors, and service providers from multiple sectors and regions. We recognize that modern slavery risks may exist anywhere in our extended supply chain.

Our Policies on Modern Slavery and Human Trafficking

We maintain strict internal policies that promote ethical standards and compliance, including:

  • A Code of Conduct that explicitly prohibits any form of modern slavery, forced labour, human trafficking, or child labour.
  • A Supplier Code of Conduct requiring all suppliers and contractors to adhere to ethical labour practices and comply with applicable laws.
  • Recruitment policies forbidding the use of worker-paid recruitment fees and ensuring employees’ rights to freedom of movement and association.
  • Procedures to ensure no worker’s original identification documents are confiscated.
  • Fair treatment policy: Commitment to fair wages, no compulsory overtime, and freedom from violence, harassment, or intimidation.

Risk Assessment and Management

The Company undertakes regular risk assessments to identify and address areas where there is a potential risk of modern slavery in our operations and supply chains. These assessments consider factors such as geographic location, industry sector risks, supplier profiles, and past audit findings.

Due Diligence Processes

We implement comprehensive due diligence processes, including:

  • Conducting supplier due diligence and audits to assess labour practices.
  • Requiring suppliers to complete self-assessment questionnaires focused on labour standards.
  • Remediating any identified issues promptly and with transparency.
  • Terminating relationships with suppliers who fail to meet our standards and do not remediate non-compliance.

Training and Awareness

The Company provides regular training to employees involved in procurement, human resources, and management to raise awareness of modern slavery risks and the signs of exploitation. Employees are trained on the Company’s policies and reporting mechanisms for suspected modern slavery.

Effectiveness Monitoring

We monitor the effectiveness of our actions through:

  • Regular review and update of policies and due diligence procedures.
  • Tracking key performance indicators such as audit findings, supplier compliance rates, and employee training completion.
  • Engaging external auditors and consultants to validate our practices.
  • Encouraging and protecting whistleblowers who report concerns relating to slavery or human trafficking.

Reporting and Communication

The Company publishes an annual Modern Slavery Statement, approved by the Board of Directors, outlining the steps taken to combat modern slavery in the preceding financial year. This statement is publicly available on our company website.

Commitment to Continuous Improvement

The Company commits to continuous improvement in combatting modern slavery through regular review of this policy, stakeholder engagement, and adaptation to new legal requirements and best practices.

Contact and Reporting

Any concerns or reports regarding modern slavery or human trafficking can be raised confidentially through the following channels:

Compliance Officer
compliance@skyrocketphytopharma.co.uk

This policy shall be reviewed annually and updated as necessary to ensure ongoing compliance with the Modern Slavery Act 2015 and related regulations.​

Code of Conduct on Modern Slavery, Forced Labour, Human Trafficking, and Child Labour

Purpose

This Code of Conduct establishes the standards of behaviour expected of all employees, directors, and business partners of Skyrocket Phytopharma when conducting business ethically, lawfully, and in compliance with the Modern Slavery Act 2015.

Policy Statement

The Company prohibits all forms of modern slavery, forced labour, human trafficking, and child labour in its operations and supply chains. All work must be voluntary, and no one shall be coerced, threatened, or deceived into employment.

Key Principles

  • No employee shall work under threat, penalty, or coercion.
  • Workers must have the right to terminate employment with reasonable notice and without penalty.
  • The Company will not employ anyone under the legal minimum working age in any jurisdiction in which it operates.
  • All employees must act with integrity, treating others with respect and fairness.
  • Any suspicions or evidence of slavery or exploitation must be reported immediately to management or via the whistleblowing channel.

Implementation

Compliance is monitored through internal audits, training programs, and management reviews. Violations may lead to disciplinary action, termination, and where appropriate, notification to authorities.

Supplier Code of Conduct

Purpose

The Supplier Code of Conduct sets out the ethical and legal standards that suppliers, contractors, and service providers must follow to do business with Skyrocket Phytopharma.

Standards

  • Suppliers must not use or permit any form of forced, bonded, indentured, or trafficked labour.
  • Recruitment practices must be transparent and lawful; workers must not pay fees or deposits to secure employment.
  • Passports or identity documents must never be withheld.
  • Wages must meet or exceed legal minimums; all working hours, overtime, and rest requirements must comply with local laws.
  • Suppliers must ensure a safe, inclusive workplace free from harassment, discrimination, or violence.
  • Suppliers must ensure freedom of movement, association, and the right to leave employment voluntarily.

Compliance and Monitoring

Suppliers must allow site inspections, self-assessment questionnaires, and audits. Breaches must be remediated immediately; failure may result in contract termination.

Recruitment Policy (Ethical Employment Practices)

Purpose

This policy ensures ethical recruitment and employment practices, eliminating exploitation and worker-paid recruitment fees.

Guidelines

  • The Company, and any external recruitment agency engaged, shall not charge any fees to workers at any stage of the recruitment process.
  • Employment terms must be clear, written, and in a language understandable to the worker before commencement of employment.
  • Background checks and right-to-work verification are conducted to comply with UK law and prevent illegal recruitment.
  • Workers must not be induced to work through deception, misrepresentation, or financial bondage.
  • Job applicants must be evaluated equally based on merit, without discrimination.

Procedure on Retention of Worker Identification Documents

Purpose

To protect workers’ rights to freedom of movement and prevent coercive employment practices.

Procedure

  • The Company strictly prohibits the confiscation or retention of workers’ passports, identification, or travel documents by the Company, agencies, or any affiliated party.
  • Employees who wish to store personal identification documents for safekeeping may do so voluntarily through a documented process, allowing full and immediate access upon request.
  • Compliance will be monitored through internal audits and supplier evaluations to verify that no improper document retention occurs.
  • Any breach must be reported immediately; disciplinary and legal action will follow non-compliance.

Fair Treatment, Wages, and Working Conditions Policy

Purpose

To ensure all workers are treated fairly, receive lawful compensation, and enjoy safe, respectful working conditions.

Key Commitments

  • Regular worker feedback and grievance mechanisms will be maintained to identify concerns of mistreatment or exploitation.
  • Wages must at least meet national minimum wage standards and be paid promptly and transparently.
  • Overtime must be voluntary, compensated, and within legal working hour limits.
  • The workplace must be free from violence, harassment, and intimidation of any kind.
  • Managers are required to maintain respectful conduct and ensure the physical and psychological safety of staff.