Modern Day Slavery Notice

Organisation

Welbeck Health Partners Ltd is a UK-based healthcare organisation providing specialist private healthcare services through a network of clinical centres and associated corporate functions in the United Kingdom.

Welbeck Group is committed to operating responsibly and ethically in all aspects of its business and maintaining robust systems and controls to prevent modern slavery and human trafficking within both its operations and its supply chains.

Organisational Structure

Welbeck Health Partners Ltd and its subsidiaries form a group of companies operating in the United Kingdom under the Welbeck brand. The organisation provides specialist private healthcare services and associated clinical support services to patients. Operational management, corporate support functions and procurement activities are primarily conducted from the organisation’s London offices and clinical centres.

Commitment

Welbeck Group has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all business dealings and to implementing effective systems and controls to safeguard against any form of modern slavery occurring within our organisation or supply chains.

To support this commitment, the Organisation maintains several internal policies and processes, including:

Recruitment: Welbeck Group operates a robust recruitment process, including right-to-work checks for all employees to ensure compliance with immigration legislation and to safeguard against individuals being forced to work against their will.

Freedom to Speak Up / Raising Concerns: Welbeck Group supports a Freedom to Speak Up culture, including an Executive Freedom to Speak Up Guardian and Freedom to Speak Up Ambassadors. A confidential reporting platform is available for staff to raise concerns safely and privately.

Anti-Bribery and Corruption: Welbeck Group maintains policies and procedures to ensure compliance with anti-bribery and corruption legislation and to promote ethical conduct across all business activities.

Anti-Money Laundering: The Organisation complies with applicable anti-money laundering legislation and maintains procedures to identify and mitigate financial crime risks.

Responsibilities

The prevention, detection, and reporting of modern slavery at Welbeck or its supply chains is the responsibility of all those working for the company or under its control. Everyone is required to avoid any activity that might lead to a breach of this policy.

If an employee believes or suspects a breach of, or conflict with, this policy has occurred or may occur, they must notify their line manager or Centre Director/Department Head or to the company’s HR department. Alternatively they must report it in accordance with the Whistleblowing policy or Freedom to Speak Up /Raising Concerns policy.

Employees are required to raise concerns about any issue or suspicion of modern slavery in any part of the business or supply chains as soon as possible. If an employee is unsure about whether a particular act, the treatment of workers or their working conditions within any of our supply chains constitutes any of the various forms of modern slavery, they should raise it with their line manager or Centre Director/Department Head.

Within the UK, people can also contact the government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.

Welbeck aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if their concerns turn out to be misplaced. Welbeck is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith a suspicion that modern slavery is, or may be, taking place in any part of its business or in any of its supply chains.

Supply Chains

Welbeck’s supply chains include suppliers and service providers across a range of sectors associated with the delivery of healthcare services, including:

• Medical equipment and devices

• Pharmaceuticals and consumables

• Surgical and medical instruments

• Furniture, fixtures and equipment (FF&E)

• Facilities and maintenance supplies

• IT and digital services

• Food and nutrition services

Outsourced operational services and support contracts

The Organisation expects all suppliers and business partners to uphold high standards of ethical conduct and labour practices. Suppliers are expected to:

• comply with all applicable laws and regulations relating to modern slavery and human trafficking;

• ensure that employment is freely chosen and that forced, bonded or involuntary labour is not used;

• prohibit child labour and comply with minimum legal working age requirements;

• provide fair wages, benefits and working conditions in accordance with applicable laws;

• maintain safe and healthy working environments; and

• respect workers’ rights to raise concerns without fear of retaliation.

Failure to meet these expectations may result in corrective action, including termination of business relationships where appropriate.

Due Diligence Process

Welbeck implements due diligence processes designed to identify and mitigate risks relating to modern slavery within its supply chains. These processes include:

Supplier Risk Assessment

Conducting risk-based due diligence on new and existing suppliers.

Applying enhanced scrutiny where suppliers operate in higher-risk sectors or geographic regions.

Reviewing suppliers’ policies and procedures relating to labour standards and ethical business conduct.

Contractual Obligations

Including contractual provisions requiring suppliers to comply with the Modern Slavery Act 2015 and applicable labour standards.

Requiring suppliers to notify the Organisation of any instances of modern slavery identified within their operations or supply chains.

Supplier Monitoring

Conducting supplier reviews and audits where appropriate.

Requesting self-assessment questionnaires from key suppliers on labour rights and ethical sourcing practices.

Training and Awareness

Providing guidance to procurement teams and relevant staff on identifying and mitigating modern slavery risks.

Encouraging suppliers to promote ethical employment practices within their organisations.

Reporting Mechanisms

Maintaining confidential reporting channels for concerns relating to unethical practices within the Organisation or its supply chain.

Investigating concerns promptly and taking appropriate corrective action.

Risk Assessment

Welbeck Group considers the risk of modern slavery occurring within its direct workforce to be low, given the nature of its operations and the regulatory framework governing employment practices in the United Kingdom.

However, the Organisation recognises that risks may arise within wider global supply chains and outsourced services. Accordingly, the Organisation continues to review its procurement practices and supplier engagement processes to mitigate potential risks.

Training

Welbeck Group promotes awareness of modern slavery risks within the Organisation and encourages employees to remain vigilant to potential indicators of exploitation.

Training and guidance relating to modern slavery and ethical supply chain practices may be provided to relevant employees, particularly those involved in recruitment, procurement and supplier management.

Effectiveness and monitoring

Welbeck Group seeks to continually improve the effectiveness of its approach to preventing modern slavery.

The Organisation may monitor effectiveness through measures including:

• completion of modern slavery awareness training for relevant employees;

• monitoring concerns raised through whistleblowing or reporting channels;

• supplier compliance with contractual labour standards; and

• periodic review of procurement and supplier due diligence processes.

The Organisation will review its approach to managing modern slavery risks on an ongoing basis and update procedures where appropriate.

Governance

Oversight of the Organisation’s approach to modern slavery and ethical supply chain practices is provided by the Executive Board.

Operational responsibility for implementing the Organisation’s procedures sits with relevant leadership and management teams across procurement, HR and operational functions.

Approval

This statement has been approved by Executive Board of Welbeck Health Partners Ltd in accordance with Section 54 of the Modern Slavery Act 2015.

Signed on behalf of the Board:

Harriet Skipworth

Director and Chief People, Procurement, Process Officer

Welbeck Health Partners Ltd

Date: 14/3/26