1. Introduction

Modern slavery is the illegal exploitation of people for personal or commercial gain. It takes various forms, such as slavery, servitude, forced and compulsory labour, debt bondage and human trafficking, often in horrendous conditions from which the victim cannot escape. All of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Businesses have a key part to play in the effort to tackle this crime and protect vulnerable workers from exploitation. PHENOX UK LTD have a zero tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chains.

Section 54 of the UK Modern Slavery Act (2015) requires commercial organisations that operate in the UK and have an annual turnover above £36m to produce a Slavery and Human Trafficking statement each year.

2. Statement

The Modern Slavery Act specifically states that any statement must include ‘the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business’

We cannot guarantee that the entire supply chain is slavery free, and this is not a requirement, but we will demonstrate the steps we have taken to assess risk and mitigate those.

3. Organisational Information

 PHENOX UK LTD is a private limited company incorporated in England and Wales in November 2020. It operates as the UK affiliate of the wider WallabyPhenox group, a specialist medical technology organisation focused on the development, manufacture and distribution of neurovascular devices used in the treatment of conditions such as ischaemic and haemorrhagic stroke. The WallabyPhenox group operates internationally, with established activities across Europe, Asia and the United States.

PHENOX UK LTD supports mainly the UK , primarily through distribution, regulatory, and commercial functions. The organisation is micro sized, with a small workforce and a clearly defined operational footprint.

4. Our Supply Chain and Procurement

As a UK based entity within a regulated healthcare sector, Phenox UK Limited’s activities are supported by a relatively limited and transparent supply chain, enabling a proportionate and risk based approach to managing modern slavery risks. Phenox UK Limited’s Approved Supplier List comprises approx. 40 suppliers, distributed across a limited number of countries: Most suppliers are located in the United Kingdom, plus single digit numbers of suppliers in Germany, Ireland, France and China.. The supplier base is therefore predominantly UK and EU-based, with minimal exposure to higher-risk geographies. This geographic concentration supports greater visibility, regulatory alignment, and ease of supplier engagement.

PHENOX UK LTD are committed to ensuring transparency in our own business and our supply chains and expect the same due diligence and commitment from our suppliers, contractors and business partners.

 When procuring goods or services we have processes in place to consider Modern Slavery risks.

We ensure we carry out supplier due diligence.

This includes:

• Robust supplier selection and policies
• Mapping of the supply chain to identify geographical areas of higher risk

 We require our suppliers, as part of the selection process and yearly auditing, to confirm adherence to our Ethical Trading, Human Rights and Labour Standards Policy and we have a Supplier Code of Conduct in place.

Supplier risk assessment:

The risk level is determined using the scale according to the global slavery index. https://www.globalslaveryindex.org

This is cross referenced with the list of goods from the US department of Labour that have been identified to be at higher risk of being produced by child or forced labour.

https://www.dol.gov/agencies/ilab/reports/child-labor/list-of-goods

Then the sector is checked against the ILO’s Global Estimates of Modern Slavery

Findings:

1 suppliers identified as medium risk

0 High Risk suppliers on the list

4 suppliers are in manufacturing and 2 are associated with logistics, warehousing, or transport, both identified risk factors

Assessment Criteria:

0 or 1 Risk factors – Low Risk

2 Risk factors – Medium Risk

3 Risk factors – High Risk

Tier 1

The nature of the organisational structure means that the risk within the business and supply chain for Tier 1 is identified as Low.

For our core product suppliers we conduct a yearly self-assessment questionnaire with them and also have mapped their Tier 1 suppliers.

UK suppliers are reviewed as part of our ISO 9001 Quality Certification within our internal audit process and is also documented in our management review meetings minutes.

This overall supply chain risk level will be reviewed yearly and reported on.

5. Policies and Processes relating to Modern Slavery

We have the following supporting documents in place: 

• Phenox UK Ltd Ethical Trading, Human Rights and labour Standards Policy,
• Supplier Code of Conduct, and
• Purchasing & Supplier Approval Process,

KPIs

We will use key performance indicators (KPIs) to measure how effective our actions are to identify and address modern slavery practices in any part of our operations and supply chains have been. 

Below are the key performance areas that we assess:

1. Governance & due diligence
2. Procurement & supply chain
3. HR practices, training & education

Against each of these focus areas we have developed KPIs that are used to assess the effectiveness of our actions. These include: 

1. The number of modern slavery cases identified and remediated
2. Update of the Modern Slavery Statement and completion of the MSAT yearly
3. Annual modern slavery risk assessment of suppliers
4. Completion rates for modern slavery awareness training

Over subsequent reporting periods, we will continue to review and enhance these KPIs and develop further metrics to assess the effectiveness of our actions, in line with continuous improvement. This will be captured and logged within our Management Reviews.

6. Training of employees around Modern Slavery

As a small company, we ensure that relevant employees receive training in:

• Ethical trading practices
• The risks and indicators of modern slavery
• The requirements of the Modern Slavery Act

We also raise awareness among suppliers and partners to support shared understanding and compliance.

7. Reporting

If a case of Modern Slavery is suspected, then the following is advised.

A suspected victim of modern slavery is not to be confronted directly as this may endanger them.

If an immediate risk to life, then call local emergency (e.g. 911 in the US, 112 in Europe, 999 in the UK).

If there is no immediate risk to life, then contact the national helpline or report it online.

Helplines and On-line Reporting

Country	Helpline	Phone	On-line
EU	Anti-trafficking hotline	See     https://www.europeanfreedomnetwork.org/hotline/
UK	Modern Slavery Helpline	08000 232 700	https://www.modernslaveryhelpline.org/report
US	National Human Trafficking Hotline	1-888-373-7888	https://humantraffickinghotline.org/en/report-trafficking

 

Employees are required to take their suspicions to their line manager.

If there are concerns around modern slavery with any of our suppliers we will first look to work with them to remedy the situation with an improvement action plan implemented and more rigorous auditing of the organisation.

If the response from any of our suppliers, here in the UK or abroad, seems inadequate and appropriate measures are not put in place to address coercion, threat, abuse, and exploitation of workers, then we would look to give that company more support, guidance and incentives to tackle the issue. This could include working with at-risk suppliers to provide training, messages and business incentives or guidance to implement anti-slavery policies.

If modern slavery is identified or suspected abroad, and resolution is not possible with the supplier, then we will engage with local Non-Governmental Organisations, industry bodies, trade unions or other support organisations to attempt to remedy the situation. If warranted, we will contact local government and law enforcement bodies. Our approach will always consider the safest outcome for the potential victims while also remember the economic influence and control which the organisation holds over those who may be committing these crimes.

If, after receiving support, the supplier is not taking the issue seriously, and it remains unresolved, then we will reconsider our commercial relationship with that supplier. These actions would then be included in the next statement produced.

8. Breaches

Any employee who breaches this statement will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Any suppliers, individuals or organisations working with us, or on our behalf who breach this policy may have their relationship or contract with us terminated.

9. Responsibility

Approved by Michael Alper, Managing Director Phenox UK LTD

Published 16.02.2026