Hygenius Modern Slavery Policy Statement

Modern slavery is a serious crime and a grave violation of fundamental human rights. It includes various forms of exploitation such as slavery, servitude, forced or compulsory labour, and human trafficking—all of which involve the denial of a person’s liberty for personal or commercial gain.

Hygenius maintains a zero-tolerance approach to modern slavery. We are committed to operating with integrity and ethics in all our business dealings and relationships. We actively implement and enforce effective systems and controls to ensure that modern slavery is not taking place within our own operations or across our supply chains.

We are equally committed to transparency in our business and supply chains and to addressing modern slavery risks in accordance with our obligations under the UK Modern Slavery Act 2015.

 We expect the same high standards from all those we work with. As part of our procurement and contracting processes, we include clear prohibitions against the use of forced, bonded or trafficked labour, or any form of slavery or servitude—whether involving adults or children. We also expect our suppliers and partners to uphold these standards throughout their own supply chains.

Scope of This Policy

This policy applies to all individuals working for or on behalf of Hygenius in any capacity, including:

• Employees at all levels
• Directors and officers
• Agency and seconded workers
• Volunteers and interns
• Contractors, consultants, agents, and third-party representatives
• Business partners and suppliers

This policy does not form part of any employment contract and may be updated or amended at any time.

Policy Responsibilities

Hygenius holds overall responsibility for ensuring this policy aligns with our legal and ethical duties. Responsibility for day-to-day implementation, compliance monitoring, and internal auditing rests with the leadership team.

Managers at all levels are expected to:

• Ensure their teams understand and follow this policy
• Provide regular training on identifying and addressing modern slavery risks
• Encourage open discussion around any concerns

Feedback, questions, or suggestions regarding this policy should be directed to the Managing Director.

Compliance and Reporting

All individuals working with or for Hygenius are required to read, understand, and comply with this policy.

Preventing, identifying, and reporting modern slavery is everyone’s responsibility. You must:

• Avoid any actions that could breach this policy
• Report concerns or suspicions immediately to your line manager or a company Director
• Alternatively, report concerns via our Whistleblowing Policy (DOC602)

Concerns should be raised as early as possible-whether related to our own operations or any tier of our supply chains.

If you’re unsure whether certain behaviour or working conditions might indicate modern slavery, speak to your line manager or a company Director.

Protection for Those Raising Concerns

We are committed to fostering a culture of openness. Anyone raising genuine concerns in good faith will be supported and protected—even if the concern turns out to be unfounded.

Detrimental treatment of whistleblowers—such as dismissal, threats, or disciplinary action— will not be tolerated.

If you believe you have suffered such treatment after reporting a concern, notify your manager immediately. If unresolved, and you are an employee, you may escalate the matter through our Grievance Procedure, found in the current employee handbook.

Final Note

This Modern Slavery Policy and Statement is designed for application across all territories where Hygenius operates, with specific reference to compliance with UK legislation. We remain fully committed to eradicating modern slavery in all its forms from our business and global supply chains.

Richard Thomas | Managing Director | 12.01.2026