Corporate Policies

Modern Slavery and Human Trafficking Statement

Date: 16/02/2026 – 15/02/2027
Last updated: 17th February 2026
  1. Introduction: This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015. Although Vermillion Health Technologies UK Limited (‘the Company’) does not currently meet the statutory turnover threshold requiring mandatory publication, we voluntarily publish this statement in anticipation of supplying the NHS and other UK public sector bodies. This statement has been prepared with regard to Procurement Policy Note (PPN) 02/23 – ‘Tackling Modern Slavery in Government Supply Chains’ – and reflects our commitment to proportionate, risk-based prevention, mitigation, and remediation of modern slavery risks.
  2. About the Company: Vermillion Health Technologies UK Limited is a UK-based start-up medical device company engaged in the development and future commercialisation of medical technologies. The Company currently has no turnover and operates with a lean structure. As operations scale, we anticipate engaging contract manufacturers, component suppliers, software providers, logistics partners, and professional service firms.
  3. Alignment with NHS Evergreen Sustainable Supplier Assessment: The Company recognises the NHS Evergreen Sustainable Supplier Assessment as a key framework for evaluating supplier sustainability maturity, including human rights and labour standards. We are committed to progressing through the Evergreen maturity levels as we scale and to embedding modern slavery risk management within our governance and supply chain oversight. We understand that modern slavery risk management forms part of the NHS’s broader net zero, social value, and ethical procurement expectations. Our systems will be designed to support transparent reporting consistent with Evergreen requirements.
  4. Governance and Policies: Consistent with PPN 02/23 expectations, we are embedding proportionate controls appropriate to our size and risk profile. These include:
    • Adoption of a Code of Conduct incorporating human rights and labour standards expectations.
    • Board-level oversight of ethical and compliance matters.
    • Supplier onboarding procedures requiring confirmation of compliance with labour laws.
    • Contractual clauses addressing modern slavery and audit rights where appropriate.
    • Whistleblowing mechanisms enabling confidential reporting.
  5. Risk Assessment: In line with PPN 02/23, we apply a risk-based approach focusing on geographic risk, sector risk (including electronics and medical device manufacturing), labour intensity, and supply chain complexity. Given our current early-stage status and limited supplier base, risk exposure is presently low but expected to evolve as higher volume manufacturing commences.
  6. Due Diligence and Mitigation Measures: Where suppliers are engaged, due diligence may include supplier self-assessment questionnaires, review of certifications (e.g., ISO 13485), screening against country risk indicators, and confirmation of compliance with applicable labour legislation. For higher-risk jurisdictions or categories, enhanced due diligence measures may include additional declarations, documentary review, or third-party audit where proportionate.
  7. Remediation and Escalation: Should indicators of modern slavery be identified, the Company will investigate promptly and take proportionate corrective action. This may include supplier engagement, corrective action plans, contractual enforcement, or termination where necessary. We recognise that PPN 02/23 emphasises not only risk identification but also effective remediation. Our approach prioritises addressing root causes where feasible.
  8. Training and Continuous Improvement: As the Company grows, modern slavery awareness training will be provided to relevant personnel, particularly those involved in procurement and supplier management. We will review this statement annually and enhance our systems as turnover increases and supply chains expand, ensuring continued alignment with NHS and UK Government expectations.
  9. Approval: This statement has been approved by the Board of Directors of Vermillion Health Technologies UK Limited.

Sustainability Policy

Last updated: 19th November 2025

At Vermillion Health, we are committed to operating our business in a manner that prioritises environmental responsibility, social equity, and economic resilience. We recognize the interconnectedness of global challenges and believe that our actions today will shape the world of tomorrow. As a small company, we understand the importance of our role in driving positive change, and we pledge to uphold the following principles in our pursuit of sustainability:

  1. Environmental Stewardship: We are dedicated to minimizing our environmental impact by adopting sustainable practices throughout our operations. We strive to reduce waste, conserve resources, and lower our carbon footprint. Our products and services are designed with sustainability in mind, aiming to promote long-term environmental well-being.
  2. Ethical Sourcing: We are committed to sourcing our materials and products in an ethical and responsible manner. We prioritize working with suppliers who share our values of fair labor practices, human rights, and environmental conservation. By partnering with ethical suppliers, we contribute to a more just and sustainable global supply chain.
  3. Community Engagement: We actively engage with and contribute to the communities in which we operate. We support local initiatives, invest in community development, and collaborate with local stakeholders to address social and environmental challenges. Our goal is to foster a positive impact and leave a lasting legacy of shared prosperity.
  4. Innovation and Education: We embrace innovation as a means to create more sustainable solutions. We invest in research and development to improve the sustainability of our products and operations. Furthermore, we are committed to educating our employees, customers, and partners about the importance of sustainability, empowering them to make informed choices.
  5. Continuous Improvement: We recognize that the journey towards sustainability is ongoing. We regularly assess our practices, set meaningful goals, and track our progress transparently. By continuously improving our sustainability efforts, we aim to inspire others and set an example for responsible business practices.
  6. Transparency and Accountability: We believe in being transparent about our sustainability initiatives and performance. We will openly communicate our achievements, challenges, and areas for improvement. By holding ourselves accountable, we invite constructive feedback and collaboration from stakeholders.
  7. Circular Economy: We are committed to promoting a circular economy by designing products that are durable, repairable, and recyclable. We encourage responsible consumption and support initiatives that extend the lifespan of products, reduce waste, and minimize resource extraction.

By adhering to these principles, Vermillion Health strives to contribute to a more sustainable and equitable future for all. We understand that our actions today have far-reaching consequences, and we are dedicated to leaving a positive legacy for generations to come.

Equality, Diversity, and Inclusion Policy

Last updated: 31 August 2023

At Vermillion Health, we firmly believe that the strength of our organization lies in the diverse backgrounds, experiences, and perspectives of our team members. We are committed to fostering a workplace that celebrates equality, embraces diversity, and promotes inclusion at every level. Our dedication to these principles is unwavering, and we pledge to uphold the following commitments:

  1. Equal Opportunity: We provide equal opportunities for all employees and job applicants, regardless of their race, colour, gender, sexual orientation, gender identity, religion, national origin, age, or disability. Our hiring, promotion, and advancement processes are based solely on qualifications, skills, and performance.
  2. Diverse Workforce: We recognize that a diverse workforce enriches our creativity, innovation, and decision-making. We are dedicated to recruiting and retaining a diverse team that reflects the communities we serve. We actively seek out and welcome individuals from different backgrounds, cultures, and perspectives.
  3. Inclusive Environment: We are committed to creating an inclusive and supportive environment where every individual feels valued, respected, and empowered to contribute their unique talents. Discrimination, harassment, and bias have no place within our workplace, and we take proactive measures to address and prevent such behaviours.
  4. Professional Development: We invest in the professional development of all our employees, providing training, mentorship, and resources to ensure everyone has the opportunity to reach their full potential. We encourage continuous learning and growth, fostering an environment of equitable advancement.
  5. Open Communication: We promote open and honest communication, encouraging all team members to share their perspectives and ideas without fear of retribution. By fostering an environment where diverse voices are heard, we enhance collaboration and decision-making.
  6. Community Engagement: We actively engage with and support the communities in which we operate. We participate in initiatives that promote equality, diversity, and inclusion both internally and externally. By championing these values beyond our workplace, we aim to contribute to positive societal change.
  7. Accountability and Transparency: We hold ourselves accountable for upholding our equality, diversity, and inclusion commitments. We regularly assess our progress, identify areas for improvement, and transparently communicate our efforts to our employees and stakeholders.
  8. Continuous Improvement: We understand that achieving true equality, diversity, and inclusion is an ongoing journey. We continually strive to learn, adapt, and improve our practices to create a more inclusive and equitable workplace for all.

By adhering to these principles, Vermillion Health aspires to create an environment where diversity is celebrated, inclusion is the norm, and every individual is empowered to excel. We recognise that our commitment to equality, diversity, and inclusion not only strengthens our organization but also contributes positively to society as a whole.

Quality Policy

Last updated: 31 August 2023

At Vermillion Health, we are dedicated to transform the way the world treats neurological problems with effective, accessible and non-pharmaceutical solutions that harness the latest in neuroscience, technology and engineering, by providing innovative products and services that are of the highest Quality, and comply with the Regulatory requirements of each of our markets.

Our Commitment:

Customer Focus: We listen to our customers, exceeding their expectations through innovative and reliable neurotechnology products.

Product Excellence: Our products undergo rigorous testing to ensure accuracy and safety, meeting the highest standards.

Continuous Improvement: We continually enhance our processes, training, and partnerships to deliver consistent quality.

Risk Management: We proactively identify and mitigate risks, ensuring the well-being of our users and adherence to regulations.

Data Security: We safeguard user data through strict security measures, in line with data protection regulations.

Ethical Integrity: Our business is built on honesty, transparency, and fairness in all interactions.

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