Modern Slavery Statement

Organisation

This statement applies to The Independent Pharmacy (referred to in this statement as “the Organisation”). The Independent Pharmacy is owned and operated by ABSM Healthcare Ltd (Company Reg. 08515600).

The Independent Pharmacy is regulated by the Medicines and Healthcare products Regulatory Agency (MHRA), The General Pharmaceutical Council (GPhC) and the Care Quality Commission (CQC).

The information included in the statement refers to the financial year 2025/2026.

Definitions

The Organisation considers that modern slavery encompasses:

• Human trafficking.
• Forced work, through mental or physical threat.
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
• Being dehumanised, treated as a commodity or being bought or sold as property.
• Being physically constrained or to have restriction placed on freedom of movement.

Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in The United Kingdom and in many cases exceeds those minimums in relation to its employees.

Organisational Structure

The Independent Pharmacy is a UK-based online pharmacy that provides confidential health consultations and sells over-the-counter and prescription medications across the UK.

Being a reliable, trustworthy and caring standard-bearer for the healthcare industry is at the core of the company’s values and this extends to it’s responsibilities in eradicating modern slavery practices in it’s supply chain.

The Organisation is run and owned by Andy Boysan and Scott McDougall who started the company in 2013.

The labour supplied to the Organisation in pursuance of its operation is carried out in The United Kingdom.

Supply Chain Structure

In order to fulfil its activities, the main supply chains of the Organisation include those related to

The Independent Pharmacy operates as a UK-based online pharmacy, sourcing medicines, medical devices and healthcare products through a structured supply chain that includes UK-licensed wholesalers, manufacturers, and approved distributors. In addition, we rely on third-party partners for services such as packaging, logistics, and IT.

Our supply chain is primarily based in the United Kingdom and the European Union, where regulation of pharmaceutical products and medical devices is robust. However, certain products, raw materials, and packaging components may originate from outside these regions. We recognise that extended global supply chains may present a higher risk of labour exploitation, including modern slavery and human trafficking.

We maintain strict supplier approval processes, requiring all suppliers and partners to be licensed, regulated, and compliant with UK law and relevant EU legislation. We expect our suppliers to uphold the same high standards of ethics and integrity, and we are committed to conducting ongoing due diligence and risk assessments to ensure that modern slavery does not take place within our operations or those of our supply chain partners.

Organisational Policies

The Organisation has the following policies which further define its stance on modern slavery:

Anti-Slavery Policy – The Organisation complies with s.54 of the Modern Slavery Act 2015 and is committed to ensuring that all its business operations are free from involvement with slavery or human trafficking.

Recruitment Policy – The Organisation carries out full and thorough proof of right to work in the UK checks for all successful job applicants along with role relevant DBS checks, helping to mitigate the risk of human trafficking and forced labour.

Whistleblowing Policy – The Organisation operates a whistleblowing policy to encourage it’s employees to report unethical business conduct or serious concerns through.

Anti-Bribery Policy –The Organisation does not tolerate bribery, fraud or other types of corruption which is made clear in the Anti-bribery Policy.

Suppliers Code of Conduct – The Organisation’s Supplier Code of Conduct makes clear the expectations on suppliers and how they must conduct themselves to ensure a continued working relationship.

Assessing and Managing Risk

The Organisation considers its main exposure to the risk of slavery and human trafficking to exist through third parties in its supply chain.

In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Due Diligence in Relation to Modern Slavery

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including;

• Requiring all suppliers to agree to our supplier code of conduct.
• Requiring all suppliers to complete a modern slavery self-assessment questionnaire.
• Carrying regular internal audits to ensure employees are paid at least National Minimum Wage and have the right to work in the UK.

Training

The Organisation provides training to those working in Commercial and Human Resources departments to recognise the signs of modern slavery and best practice to adhere to the Modern Slavery Act 2015.

Monitoring and evaluation

The Organisation will be able to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains through monitoring supplier self-assessments, internal audits, the number of whistleblowing cases raised and reviewing our processes annually.

Steps

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

• In September 2025, a review of the controls of its suppliers has taken place.
• Introduction of a supplier onboarding process to ensure relevant checks are carried out.
• New training provided to Commercial and Human Resources employees.

This statement is made in pursuance of s.54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Signed by:

Andy Boysan

Scott McDougall