1. Purpose

This Anti-Slavery and Human Trafficking Statement (“Statement”) is made by Avania UK, Ltd, on behalf of the Avania group of companies operating and carrying on business within the United Kingdom (“Avania”), pursuant to the Modern Slavery Act 2015 for the financial year ending 31 December 2023.

Avania is committed to preventing slavery and human trafficking within our operations and supply chains. We acknowledge our responsibility to take proactive steps to ensure that slavery and human trafficking is not taking place in any part of our business.

2. Scope

This Statement applies to all entities, operations, and employees of Avania.

3. Summary

Avania is an integrated global, full-service Contract Research Organization (CRO) with specialized expertise in medical device novel technology, and combination products. We advance products from feasibility all the way through post-approval in analytics, clinical trials, consulting, medical writing, quality management, regulatory, reimbursement, and more.

As a growing company, we are actively developing a comprehensive governance and risk management framework on a global scale.

3.1 Policies

All Avania entities must adhere to group policies which emphasize our dedication to upholding national and international laws and regulations concerning human rights and labor laws. The following policies are applicable to anti- slavery and human trafficking:

  • POL-027 Code of Conduct Policy
  • POL-030 Human Rights Policy
  • POL-OIO Anti-Bribery and Corruption Policy
  • POL-028 Whistleblowing Policy

3.2 Reporting

3.2.1. Avania strongly encourages all employees and suppliers to seek advice regarding ethical and compliance matters, and to report any potential breaches of our codes, policies, and legal obligations. To facilitate the early identification and resolution of issues, we promote open communication.

3.2.2 Avania has several avenues to report concerns, as detailed in our Whistleblowing Policy. Additionally, employees are encouraged to contact their line managers, a member of the local leadership team, the Human Resources department, or the Legal department if they wish to.

3.2.3 All reported concerns undergo thorough investigation, and appropriate actions are taken upon identification and substantiation of violations. Importantly, we strictly prohibit any form of retaliation against individuals who raise concerns in good faith.

3.3 Due Diligence

3.3.1 Avania does not directly supply goods or materials. The clinical research field in which we operate is rigorously regulated and undergoes regular compliance audits by regulatory bodies and our client base. We therefore assess the risk of slavery or human trafficking in our supply chain and business as minimal.

3.3.2 While we believe that there is a low direct risk of involvement in slavery and human trafficking in our business and supply chain, we employ a risk-based approach, which we continue to develop.

3.3.3 Avania continually revises existing policies and is dedicated to implementing new ones aimed at identifying, evaluating, and monitoring potential areas of risk related to human rights breaches, including slavery and human trafficking.

3.3.4 Avania is currently implementing measures to gain insights into the practices of our suppliers and third- parties that we engage with, including our supplier survey form. Our commitment is to review and assess all relationships in our supply chain to ensure compliance with anti-bribery and slavery laws and regulations.

3.3.5 Additionally, Avania’s commercial contracts incorporate language that requires third parties and clients to operate in an ethical and legal manner. Our legal team will continue to improve our standard contractual terms to include these principles and will continue to review our older contractual arrangements to update with the relevant provisions.

3.3.6 Avania’s Clinical teams conduct site selection visits to verify the safe operations of external health organizations. Additionally, they perform thorough audits to evaluate the suitability of both personnel and facilities.

4. Training

Avania is in the process of implementing a full range of compulsory training modules covering a variety of ethics and compliance topics for all employees.

5. Approval

This statement has been approved by the Directors of Avania UK, Ltd, who acknowledge the responsibility to update and publish it annually.

Sapna Hornyak

Sapna Hornyak

David Stickland

David Stickland

Sarah Robinson

Sarah Robinson