Vitalograph Modern
Slavery Statement 2023

I. INTRODUCTION

This Modern Slavery Statement is made pursuant to supply chain diligence, specifically section 54 of the UK Modern Slavery Act 2015, and Article 4 of the European Convention on Human Rights. Furthermore, Vitalograph commits to uphold such human rights principles in all territories in which it operates. The Statement is issued on behalf of Vitalograph (UK) Ltd., UK company number 01955895 and its subsidiaries; Vitalograph Ltd., UK; Vitalograph (Ireland) Ltd.; Vitalograph Inc., USA; Vitalograph GmbH, Germany and Vitalograph Japan Co. Ltd. (“Vitalograph”).

Vitalograph recognizes that modern slavery, including human trafficking, forced labour, bonded labour, child slavery, and hazardous child labour can occur in every industry and sector.

Vitalograph acknowledges and accepts its responsibility to take meaningful action to prevent slavery in any form, from occurring within our own organisation as well as in our supply chain.

II. ORGANISATION

Vitalograph is a global organisation, founded in 1963, with over 400 employees, a factory in Ennis, Ireland and headquarters in Maids Moreton, Buckingham. There are sales and service offices in the UK, Ireland, USA, and Germany.

Vitalograph is dedicated to its mission to improve patient lives through supporting our customers and partners by designing and manufacturing market leading products and services. For more than 60 years, Vitalograph has been a world leader in respiratory diagnostic solutions, manufacturing and supplying high quality spirometers and respiratory medical devices. Vitalograph products aid the detection, diagnosis and management of respiratory conditions and are chosen by medical professionals in healthcare and occupational health settings worldwide. The Vitalograph clinical trial services team supports clinical trials for some of the world’s leading pharmaceutical companies, biotechs and contract research organisations.

III. SOCIAL RESPONSIBILITY

To achieve its mission, Vitalograph works with and supports many partner organisations and is proud to support, among others:

• The International Primary Care Respiratory Group (IPCRG)

• The American Thoracic Society

• Asthma + Lung UK (A+LUK)

• The Asthma Society of Ireland

• The American Lung Association

• The Fresh Air Project

• Medecins sans Frontieres

• The Kansas City Foundation for Pulmonary Fibrosis

• Cystic Fibrosis Ireland

• Our local universities and schools (University of Limerick, University of Buckingham, The Royal Latin School)

Community groups and local charities in Buckingham, Kansas and Ennis including sport and youth organisations, schools, and social welfare groups.

III. SUPPLY CHAIN

Vitalograph’s internal supply chain consists of a factory in Ennis, Ireland.

Warehouse and distribution centres are situated in the US, Germany, UK, and Ireland.

Vitalograph’s external supply chain is complex due to the diverse nature of its products. Vitalograph has approximately 150 critical suppliers of components and finished products across a variety of industry sectors and geographic locations.

IV. POLICIES

Vitalograph is committed to the highest standards of corporate responsibility in general, and the elimination of modern slavery in particular.

Vitalograph’s commitment is based on the internationally agreed principles for sustainable development around human rights (including labour rights), the environment (including climate), and anti-corruption. The principles are listed by the UN Global Compact, with which Vitalograph aligns. They are made operational through the UN Guiding Principles on Business and Human Rights (“UNGPs”) and the OECD Guidelines for Multinational Enterprises (“OECD”). Specifically:

1. Employee Handbook

The Vitalograph employee handbook contains Vitalograph’s Anti-Slavery policy which specifically recognises, and addresses issues related to modern slavery. It applies throughout the organisation and guarantees:

• a workplace free from forced or involuntary labour,

• a workplace free from child labour, and

• compensation to employees which complies with all applicable wage laws relating to minimum wages, overtime hours and legally mandated benefits.

2. Supplier Code of Conduct

Vitalograph requires critical suppliers to submit a company code of conduct confirming their commitment to corporate social responsibility (including clauses similar to those mentioned above in Vitalograph’s Employee Handbook), or to sign Vitalograph’s Supplier Code of Conduct.

3. Whistleblower Policy

Vitalograph encourages all (employees, customers, suppliers, and external parties) to report issues of concern that may include violations of any of the ethical commitments in areas such as the environment, human and labour rights, equality and diversity, health and safety, business ethics, anti-corruption, conflict of interest and professional behaviour.

VI. DUE DILIGENCE

1. New Supplier Qualification and Approval

Vitalograph’s due diligence efforts begin during the initial supplier qualification and approval process. Representatives responsible for sourcing take industry sector and geographic location of the supplier (among other factors) into consideration when assessing initial risks and appropriate mitigating controls if the supplier is approved. Efforts are made to approve suppliers in countries and/or regions which Vitalograph is familiar with, and which pose lower risks in general and specifically regarding social responsibility including human rights abuses.

On-site qualification audits are required for critical suppliers of finished medical devices or components of medical devices manufactured to our design. As part of those audits, parties responsible for sourcing observe working conditions and may ask for documentation of working hours, overtime, training, and other work-related elements.

Critical suppliers are required to have a code of social responsibility or sign off on Vitalograph’s Supplier Code of Conduct to be approved as a Vitalograph supplier.

Best endeavours are made to ensure that ad hoc purchases from non-approved vendors are ethically sourced, e.g. by checking company websites or selecting well-known and reputable brands.

2. Supplier Selection

When selecting a supplier, parties responsible for sourcing first consider previously approved suppliers. This serves to keep the number of suppliers stable and reduce the risks in all areas as Vitalograph is familiar with the suppliers’ modus operandi in their respective industry and regarding social responsibility.

3. Supplier Follow-Up and Evaluation

Vitalograph processes require regular follow-up and evaluation of suppliers, the frequency of which depends on a variety of risk factors.

Vitalograph monitors quality and delivery performance monthly and requires critical vendors to complete a surveillance questionnaire as part of a bi-annual evaluation process. Non-critical qualified suppliers are required to complete the surveillance questionnaire every 3 years. On-site audits are a tool used by sourcing representatives to follow up and evaluate selected suppliers.

VII. COMPETENCY AND TRAINING

1. Sourcing Parties

Vitalograph’s sourcing responsible parties receive training in all relevant processes and those processes include recognizing, evaluating and mitigating risks related to supplier working conditions and human rights compliance.

2. Company-Wide Training

All employees receive training in the Vitalograph Employee Handbook as part of the onboarding process. The Handbook, as mentioned above, includes sections related to working conditions. However, considering the increased importance and focus on modern slavery and other social responsibility issues, Vitalograph intends to start the process of developing appropriate, focused training programs to increase awareness and competency in these specific areas.

VIII. CONCLUSION

Vitalograph believes that its mission, processes, modus operandi and focus on working with stable, well-established suppliers in low-risk geographic locations has significantly reduced the risk of modern slavery in the organisation and supply chain.

Vitalograph has never discovered any actual or suspected cases of modern slavery in its organisation or supply chain. Vitalograph recognises that vigilance is critical and shall continue to improve in those areas which require more focus to ensure that modern slavery never occurs within our business operations or with those we do business with.

Vitalograph (UK) Ltd.

Last updated December 2023

Signature on behalf of board of directors