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Ascot Pharmaceutical Ltd and its subsidiaries (“Ascot” / “We” / “Our” / “Group”) are firmly committed to implementing effective measures and due diligence procedures to prevent any form of modern slavery or human trafficking within our operations or supply chains.
This statement has been prepared in accordance with Section 54(1) of the Modern Slavery Act 2015 and sets out Ascot’s position on slavery and human trafficking for the financial year ending 31 December 2024.
Ascot Pharmaceutical is a growing consumer healthcare organisation dedicated to empowering individuals to improve their health and wellbeing by making our trusted and proven brands available across global markets.
We achieve organic growth by investing in our key brands and distribution channels, pursuing relevant innovation, and expanding selectively into new geographic regions to extend our market reach. From time to time, we also enhance our growth through strategic, complementary acquisitions.
Headquartered in the United Kingdom, the Group employs approximately 285 people across Europe, North America, and the Asia-Pacific region. Our operational model is based on outsourcing both manufacturing and distribution.
Ascot Pharmaceutical Ltd is the ultimate parent company of the Group, with shares admitted to trading on the Alternative Investment Market of the London Stock Exchange. Ascot operates through subsidiaries incorporated in the UK, mainland Europe, Hong Kong, China, Singapore, Thailand, the Philippines, and the USA.
Our supply chains comprise the following:
Raw material/API suppliers
Component suppliers
Contract manufacturers
Freight forwarders
Warehousing and storage
Approximately 64% of components for Ascot’s products are sourced in Europe, around 16% from the USA, and roughly 20% from suppliers and manufacturers based in China and South-East Asia.
As part of a broad value chain, our routes to market include retail, e-commerce, healthcare providers, and distribution networks.
Ascot Pharmaceutical is fully committed to eliminating any possibility of modern slavery or human trafficking in our business and supply chain. Our anti-slavery efforts are guided by our corporate value of Integrity and our commitment to responsible and ethical business conduct.
Responsibility for the anti-slavery and labour exploitation programme lies with our Legal Team, under the overall accountability of the General Counsel and Company Secretary. The Head of Legal oversees all related policies and employee training, reporting to the ESG Lead, ESG Committee, and ultimately to the Board.
We recognise that investors are increasingly focused on environmental, social, and governance (ESG) factors, as responsible investment contributes to long-term stability. Ascot will continue to share social responsibility developments through discussions and public reports on our website.
Aligned with our PRAISE values — Performance, Realism, Accountability, Integrity, Skill, and Entrepreneurship — Ascot maintains a comprehensive suite of policies to prevent, identify, and address modern slavery within our business and supply chain. These policies are regularly reviewed and enhanced with input from internal experts, suppliers, and external advisors.
Key policies include:
Anti-Slavery Policy – Reinforces our commitment to ethical and transparent business practices. It outlines the responsibilities of employees and suppliers and provides a clear escalation process for raising concerns.
Employee Code of Conduct – Defines behavioural standards expected from all representatives of Ascot. It includes specific guidance on recognising and preventing modern slavery and applies to all employees, contractors, agency workers, and directors.
Partner Code of Conduct – Applies to all external partners providing goods or services. It explicitly details Ascot’s expectations regarding the detection and prevention of modern slavery in our partners’ workplaces and supply chains. It was recently updated to align with the ETI Base Code, a recognised international labour standard.
Anti-Bribery and Corruption Policy – Establishes Ascot’s zero-tolerance stance on bribery and corruption, ensuring integrity in all domestic and international operations.
Speak-Up Policy – Encourages openness and accountability by providing a confidential channel for employees and contractors to raise concerns. In partnership with Safecall, an independent third-party helpline, reports can be made anonymously, including those related to modern slavery.
Human Rights Policy – Currently being implemented to align our practices with internationally recognised human rights standards, emphasising equality, dignity, and respect for all individuals.
To identify and mitigate risks, Ascot has established a robust due diligence framework, which includes working with external advisers and digital compliance platforms to:
Identify and assess potential risk areas
Mitigate and monitor risks in our supply chains
Protect whistleblowers
In 2024, we engaged a compliance specialist to review our Know Your Client/Supplier processes, adverse media monitoring, and escalation procedures.
All Ascot-manufactured products comply with Good Manufacturing Practice (GMP) standards, ensuring the highest quality across products, facilities, and workforce. We conduct regular site visits and compliance checks (including modern slavery audits) in addition to government inspections. In 2024, we performed five in-person modern slavery audits on key suppliers, all of which raised no human rights concerns. A further five audits are planned for 2025.
Our healthcare supplier onboarding process includes financial, commercial, and quality assessments with modern slavery questionnaires and audits. We require compliance with ISO 13485:2016 and Medical Device Distribution Standards, and for cosmetics, ISO 22716.
In the USA, Ascot adheres to 21CFR800 and 21CFR100 standards, which mandate ethical labour practices and the prevention of slavery and trafficking.
All new supplier contracts with Ascot include modern slavery warranties and undertakings. Suppliers are required to confirm compliance and ethical operation. Where concerns arise, Ascot prioritises resolution and continuous improvement, always safeguarding victims’ welfare. If issues cannot be resolved, we will responsibly disengage from the partner.
Ascot’s roles are primarily technical and skilled, presenting a low risk of targeting by traffickers. Nonetheless, we remain alert to any vulnerabilities within our workforce.
Our recruitment process includes Right to Work, visa, and qualification checks, ensuring salaries are paid directly into employees’ own accounts. The HR department maintains a strong focus on employee welfare, with open communication channels to address any concerns promptly. We only work with reputable employment agencies when hiring temporary or contract staff.
With an estimated 50 million individuals affected by modern slavery globally, Ascot remains aware that these risks are evolving. External pressures such as inflation, conflict, and climate change can increase vulnerabilities. Key areas of focus include:
Contract Manufacturing Organisations (CMOs): High-risk due to geographic and operational complexity. Ascot maintains strong oversight through audits and regular engagement.
Warehousing and Logistics: Certain roles such as pickers and drivers remain vulnerable. Ascot ensures partners maintain fair employment practices and worker protections.
Raw Materials and Minerals: Sourcing from regions with known labour exploitation risks is closely monitored. Ascot is developing a deeper risk assessment programme and supplier collaboration plan.
Non-Resale Goods and Services: Outsourced cleaning, maintenance, and security are managed through local hiring and fair pay policies.
All Ascot employees complete mandatory modern slavery awareness training at induction and annually thereafter. Specialised workshops are also delivered to high-risk teams such as sourcing and quality, in partnership with Slave-Free Alliance, to identify and address potential red flags during audits and supplier visits.
We measure our performance through key indicators including:
Supplier vetting and ongoing risk-based monitoring
Scheduled and ad-hoc subcontractor inspections
Active Speak-Up mechanisms
Regular training and refresher sessions
Remedial actions when required
Over the past year:
No slavery or trafficking incidents were identified.
No related Speak-Up or Anti-Slavery reports were filed.
No remedial actions were necessary.
Our Board remains confident in the effectiveness of our policies and training.
In 2023, Ascot Pharmaceutical entered a three-year partnership with Slave-Free Alliance, a social enterprise owned by Hope for Justice. This collaboration strengthens our ability to identify and mitigate slavery risks within our supply chains.
In 2024, we completed a high-level risk assessment of our top 15 suppliers to prioritise anti-slavery actions, focusing on high-risk geographies and sectors. We have since developed enhanced due diligence guidelines for engaging with suppliers in higher-risk regions to improve transparency and ethical standards.
In August 2024, Ascot Pharmaceutical became a signatory member of the UN Global Compact. We are committed to submitting our first Communication on Progress by 31 July 2025. Through this global framework, we uphold principles promoting labour rights, including freedom of association, elimination of forced and child labour, and equality in employment.
For the year ahead, Ascot Pharmaceutical plans to:
Deepen engagement with identified high-risk suppliers
Expand training and awareness across all business units and partners
Implement recommendations from the Slave-Free Alliance Gap Analysis
Finalise and launch a Group-wide Human Rights Policy
This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and represents Ascot Pharmaceutical Group’s slavery and human trafficking statement for the financial year ending 31 December 2024.
Approved by the Board on 24 January 2025.
[Authorised Signatory]
Chief Executive Officer
Ascot Pharmaceutical Ltd
24 January 2025
