Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act

2015 and relates to actions and activities for the financial year ending 01 January 2022.

Fortress Clinical Laboratory is committed to preventing slavery and human trafficking  violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our  supply chain to comply with our values.

Organisational structure

Fortress Clinical Laboratory is the subsidiary of the Fortress Holding Group, the parent company being Fortress Diagnostics, and has business operations in the United Kingdom. We operate in the Healthcare sector.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chain.

Fortress Clinical Laboratory’s suppliers play an important role in the success of our organization. We work with suppliers who provide Laboratory equipment, raw materials, goods, and services driving risk management and quality performance throughout the supply chain.

For more information about the Company, please visit our website: www.fortressdiagnostics.com.

Fortress Clinical Laboratory requires that each of its suppliers comply with all laws, rulings and regulations in the jurisdictions where they do business. That includes laws related to equal opportunity and nondiscrimination, and laws prohibiting human trafficking and slavery.

Fortress Clinical Laboratory employees are encouraged to report to management if they suspect that any supplier is engaging in unethical behavior. If Fortress Clinical Laboratoryverifies that any supplier is in violation of applicable laws, Fortress Clinical Laboratory has the right to terminate the agreement with the supplier.

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

Recruitment and selection policy – We conduct checks on all prospective employees to verify that they are eligible to work in the UK.

Supplier code of conduct – We operate this policy to ensure our suppliers operate in full compliance with the laws, rules and regulations of the countries in which they operate, and to seek similar commitments across their own supply chain.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Our Code of Business Conduct includes explicit prohibitions against trafficking in persons, sex trafficking, forced labour and fraudulent practices in recruiting by Fortress employees and added requirements for Fortress staff to closely scrutinise the operations of our supply chain to ensure their compliance with this requirement. Our Supplier Code of Conduct, which is applicable to all Fortress supplier contracts and orders, bans the use of child labour, forced labour and human trafficking by its supply chain.

Fortress employs robust supplier selection, supplier qualification, and sustainability management processes which require key suppliers to disclose details about their own policies and procedures to prevent and detect modern slavery and human trafficking. Fortress is committed to enforcing and expanding its disclosure requirements with suppliers as part of its ongoing supplier management programs.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

External supplier audits.

• Our due diligence procedures aim to:
• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains.
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
• Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We have a dedicated global compliance team, which consists of representatives from our Human Resources (HR), HR Consultants, and Legal Consultants, with assistance from Fortress’s Purchasing and Supplier Quality Department.

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

Modern slavery considerations will be included, where appropriate, as part of Fortress’s due diligence and risk assessment processes, including when commencing activities in new countries or industry sectors, entering new business relationships or investments or engaging new suppliers.

Fortress will take a risk based approach in accordance with its processes and procedures to deciding what level of due diligence is required to understand, assess and address potential modern slavery practices associated with countries, industry sectors, business relationships, investments and suppliers. A more in-depth due diligence will be conducted if initial inquiries identify any modern slavery ‘red flags’

Training, Awareness and Reporting

Fortress is committed to building awareness among its Employees in relation to modern slavery related matters, including this Policy and how to report modern slavery concerns. Fortress Employees responsible for procurement and supplier relationships will be provided with training on how to implement the commitments in this Policy in their roles.

Our internal policies and procedures aim to ensure that our employees understand and comply with all laws, rulings, and regulations in their area of business. To ensure an understanding of the risks of modern slavery and human trafficking in our supply chain and our business, we provide ethics and compliance training to our management team.

Managers are required to be trained on key legal issues affecting our global business and that includes laws prohibiting human trafficking and slavery. Employees also are encouraged to seek guidance when they have questions or concerns regarding our policies and procedures through our HR department. Employees may also use these channels to report any concerns or suspicions related to company or supplier actions. The HR department is available to employees and other third parties to raise issues or concerns regarding various compliance employment and legal issues, including those involving modern slavery and human trafficking.

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows: We will contact suppliers to enquire about their modern slavery practices every 36 months. The statement was approved by the board of directors.