This statement has been published in accordance with the U.K. Modern Slavery Act 2015 and sets out the steps that Shanghai TMRWD Health Co., Ltd. has taken to prevent modern slavery and human trafficking in their business and supply chains during the fiscal year ended June 30, 2021 (“fiscal 2021”).

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Our Business and Supply Chains:

Shanghai TMRWD Health Co., Ltd. is a globally integrated healthcare services and products company headquartered in Shanghai, China providing customized solutions for hospitals, healthcare systems, pharmacies, ambulatory surgery centers, clinical laboratories, physician offices and patients in the home. We manufacture, source, and distribute TMRWD Health branded medical, surgical and laboratory products, which are sold in the United States, Canada, Europe, Asia, and other markets. In addition to distributing TMRWD Health branded products, we also distribute a broad range of medical, surgical and laboratory national brand products in the United States and Canada. Our product supply chains are extensive and global, numbering thousands of suppliers. We purchase pharmaceuticals and medical products through our supply chains as well as various components, compounds, and raw materials, including oil-based resins, pulp, cotton, latex, and other commodities, for our manufacturing businesses.

Policies and Contractual Controls:

TMRWD Health shares global concerns related to the fair and equitable treatment of all peoples. Global Human Rights and Labor Standards. Our Global Human Rights and Labor Standards policy establishes requirements for global conduct related to human rights and labor standards. This policy is informed by internationally recognized instruments setting forth human rights and labor standards. In developing this policy, we have, among other things, considered the International Bill of Human Rights, the United Nations Guiding Principles on Business and Human Rights, the Ten Principles of the United Nations Global Compact and the International Labour Organization Declaration on Fundamental Principles and Rights at Work. The policy complements our Standards of Business Conduct, Vendor Code of Conduct and contractual controls discussed below, which contain additional requirements addressing modern slavery and human trafficking. This policy states that TMRWD Health strives to conduct its business in a manner that demonstrates respect for internationally recognized human rights and the dignity of all people.

Among other things, the policy indicates the following expectations for TMRWD Health personnel: 

• a workplace that is free from harassment and discrimination;
• no coerced, bonded, indentured or prison labor; all work will be voluntary without fear of abuse and employees will not be required to lodge deposits of their identity papers
• no child labor; 
• compliance with local and national minimum wage, overtime and benefits laws and regulations;
• working hours consistent with local and national laws and regulations and not otherwise excessive;
• a healthy, clean and safe work environment;
• compliance with applicable immigration laws and regulations;
• freedom of association; and
• compliance with applicable laws and regulations, including those related to employee records and employee privacy.

Vendor Code of Conduct:

For our suppliers, we have adopted a Vendor Code of Conduct which sets forth the basic requirements that all vendors, distributors, agents, suppliers, representatives and other business partners and their employees, directors, officers, agents, representatives and subcontractors must comply with to do business with us. The Vendor Code of Conduct sets forth clear expectations in the areas of modern slavery and human trafficking. Our Vendor Code of Conduct requires our suppliers to:

• not use child labor;
• fairly compensate employees;
• provide workers with rest days and leave privileges and otherwise not require excessive working hours;
• not use forced labor, whether in the form of indentured, bonded or prison labor;
• not support any form of human trafficking or involuntary labor through threat, force, fraudulent claims or other coercion;
• not engage in acts of verbal or physical harassment and not discriminate;
• only employ workers with a legal right to work; suppliers are required to adopt compliance procedures and regularly audit employment agencies from whom they obtain workers to monitor compliance with this policy; 
• not require employees to lodge “deposits” or identity papers; and
• permit employees to freely resign their employment. 

Under the Vendor Code of Conduct, suppliers must educate their subcontractors on these principles and require their subcontractors to agree to the Vendor Code of Conduct. The Vendor Code of Conduct also requires suppliers to establish processes to enable their employees to report concerns or illegal activities, which suppliers must investigate and then take appropriate corrective action.

The Vendor Code of Conduct encourages suppliers and their employees to contact us with questions or concerns, through the contact information indicated therein, and indicates that we will not tolerate any retribution or retaliation against any individual who has, in good faith, sought out advice or has reported questionable behavior or a possible violation.

Contractual Controls. We include provisions in our applicable supplier contracts requiring compliance with Federal Acquisition Regulation (“FAR”) and Defense FAR Supplement human trafficking prohibitions and requirements for U.S. federal government contracts. In addition, our standard sourcing contracts for medical products require suppliers to not use child labor or forced or prison labor. Compliance with our Vendor Code of Conduct also is a standard term in our supplier contracts and purchase orders.
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Due Diligence and Supplier and Supply Chain Audits:‍

We have been enhancing our due diligence procedures for human rights and labor matters, including with respect to suppliers for the segment’s self-manufactured and sourced medical products. We have been enhancing processes for risk assessments, including supplier questionnaires and on-site audits, and have focused on suppliers with the highest inherent risk for human rights and labor standards as well as for environmental, health and safety and business ethics issues.

This statement was approved by the Board of Directors of Shanghai TMRWD Health Co., Ltd. on August 2, 2021.