Modern Slavery and Human Trafficking Statement

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 31 March 2025.

DemDx Limited recognises the importance of protecting individuals from harm and exploitation and is committed to acting responsibly, ethically, and in a manner consistent with NHS and public-sector safeguarding values. This statement sets out the steps taken by the Company during the financial year to mitigate the risk of modern slavery and human trafficking and is reviewed periodically.

DemDx Limited ('the Company', 'we', 'us' or 'our') 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 and Supply Chains

DemDx Limited has business operations in the United Kingdom.

We operate in the healthcare sector. The nature of our supply chains is as follows: We work with a number of key direct suppliers, who provide us with goods, such as equipment for our premises, and services, such as outsourced business processes, IT software and marketing services.

For more information about the Company, please visit our website: Home.

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. Certain roles require a Disclosure and Barring Service (DBS) check where employees may be working with vulnerable people.
  • 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.
  • Whistleblowing policy – We operate this policy so that employees are able to raise concerns about how staff are being treated or practices within our business or our supply chains without fear of reprisal.
  • Staff code of conduct – We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.
  • Procurement policy – We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our procurement policy and supporting procedures set out controls and checks undertaken to help verify this.
  • Safeguarding policy – This policy highlights the potential risks of modern slavery and human trafficking, including how to identify signs of exploitation and how to report concerns.

These policies support safeguarding and ethical standards expected of organisations working with or alongside the NHS and are reviewed periodically.

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

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:

  • Risk-based consideration of modern slavery risks when onboarding new suppliers
  • Obtaining assurances from key suppliers regarding compliance with modern slavery legislation
  • Ongoing monitoring of supplier relationships where appropriate

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.
  • Provide protection for whistleblowers.

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:

  • Evaluating the slavery and human trafficking risks of each new supplier.

Based on this assessment, the overall risk is considered low. However, we recognise the importance of continued vigilance and proportionate oversight, particularly in the context of healthcare services.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.

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:

  • Confirmation from key suppliers regarding compliance with modern slavery legislation
  • Periodic review of supplier risk assessments
  • Monitoring of training or awareness activity among relevant staff
  • Review of any concerns raised relating to modern slavery

Next Steps

In the next financial year, we intend to take the following steps to tackle slavery and human trafficking by:

  • Enhancing staff awareness of modern slavery and safeguarding risks
  • Reviewing supplier engagement and procurement practices
  • Updating relevant policies and documentation where appropriate

Approval

The statement was approved by the board of directors.

This statement was approved by the Board of Directors of DemDx Limited on 25th November 2025

Signed:

Lorin Gresser
Director
DemDx Limited