Modern Slavery Statement

The Company

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

The Independent Pharmacy is regulated by The General Pharmaceutical Council (GPhC) and the Care Quality Commission (CQC).

The information contained within this statement relates to the period from 1st October 2025 to 30th September 2026.

Definitions

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

The Company 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 Company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company 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.

Company 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 its responsibilities in eradicating modern slavery practices in its supply chain.

The Company has been owned and operated by Andy Boysan and Scott McDougall since 2013.

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

Supply Chain Structure

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.

In order to fulfil its activities, the main supply chains of the Company include pharmaceutical wholesalers and manufacturers.

The Company’s 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. It is recognised that extended global supply chains may present a higher risk of labour exploitation, including modern slavery and human trafficking.

The Company maintains strict supplier approval processes, requiring all suppliers and partners to be licensed, regulated, and compliant with UK law and relevant EU legislation. It is expected that suppliers uphold the same high standards of ethics and integrity, and the Company is committed to conducting ongoing due diligence and risk assessments to ensure that modern slavery does not take place within its operations or those of its supply chain partners.

Company Policies

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

Anti-Slavery Policy – The Company 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 Company 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 Company operates a whistleblowing policy to encourage its employees to report unethical business conduct or serious concerns.

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

Suppliers Code of Conduct – The Company’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 Company considers its main exposure to the risk of slavery and human trafficking to exist through third parties in its supply chain.

The Company considers its direct labour risk to be low due to all employees being recruited and employed in the United Kingdom. Supply chain risks are considered higher due to the potential for the manufacture of products, packaging materials and raw materials in countries where labour protections may be less robust.

Due Diligence in Relation to Modern Slavery

The Company 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 Company 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 Company measures its effectiveness through monitoring supplier assessments, internal audits, whistleblowing reports and annual reviews of its processes.

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

Steps Taken 2025/2026

In accordance with section 54(4) of the Modern Slavery Act 2015, the Company took the following steps to ensure that modern slavery was not taking place:

• In 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 on Modern Slavery introduced to the Commercial and Human Resources teams.

This statement is made in pursuance of section 54(1) of the Modern Slavery Act 2015 and is reviewed each year in April to ensure it remains accurate and effective.

Next Steps for 2026/2027

Looking forward into 2026/2027, the Company is committed to continue to strengthen its approach in preventing modern slavery and will take the following actions in the coming financial year.

• Expand its monitoring of suppliers by increasing the frequency and scope of supplier reviews, focussing on higher risk categories.
• Fully integrate its supplier onboarding processes across the Company to all areas, ensuring consistent due diligence before engaging with a supplier.
• Assess emerging risks by monitoring changes to legislation, global supply chain conditions and sector specific risks, to ensure its approach remains relevant and up to date.
• Renewal of training to Commercial and Human Resources teams, ensuring learning has been embedded into ways of working. 

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

Board Approval

This statement was approved by the Board of Directors of ABSM Healthcare Ltd on 13/10/2026.

Signed:

Andy Boysan & Scott McDougall

Directors

ABSM Healthcare Ltd