Modern Slavery & Human Trafficking Statement

1. About Euro Biom

Euro Biom Ltd is a UK-registered pharmaceutical wholesale distributor operating under MHRA Wholesale Dealer Authorisation WDA(H) 59239. Our operating address is Unit-5 Skyport Drive, Harmondsworth, London, UB7 0LJ, and we supply pharmaceutical products internationally to hospitals, government health ministries, NGOs and healthcare institutions across more than 40 countries.

Our operations involve the procurement, supply and export of pharmaceutical products sourced from verified and authorised manufacturers and distributors within the UK licensed supply chain. We employ a small, specialist team and work with a limited number of carefully selected logistics and service partners.

2. Our Supply Chains

Our pharmaceutical supply chain is tightly controlled and subject to regulatory oversight at every stage. We source medicines exclusively from manufacturers and wholesale distributors that hold valid manufacturing authorisations or wholesale dealer authorisations issued by the MHRA.

Each supplier undergoes qualification checks before we engage with them, including verification of their regulatory licences, Good Manufacturing Practice or Good Distribution Practice compliance status, and corporate standing. We do not source products from unregulated markets, and we do not engage intermediaries or brokers whose provenance we cannot verify.

Beyond pharmaceutical sourcing, our broader supply chain includes logistics providers for temperature-controlled air freight and last-mile delivery, IT and digital service providers, and professional services firms for legal, accounting, and compliance advisory work. These relationships are managed under formal agreements and reviewed regularly.

3. Our Policies and Due Diligence

Euro Biom maintains the following policies and procedures that are relevant to identifying and preventing modern slavery risks:

• Supplier Qualification Procedure: all pharmaceutical suppliers are verified against MHRA databases before onboarding. We assess each supplier's regulatory standing, corporate governance, and compliance history before any commercial engagement.
• Good Distribution Practice (GDP) Compliance: our entire operation is subject to GDP requirements, which include documented quality management systems, personnel training records, and full traceability across the supply chain. GDP compliance inherently requires us to maintain visibility and accountability over every party involved in the handling of our products. Our commitments under GDP are documented in our published Quality Policy.
• Terms & Conditions of Sale: our published Terms & Conditions of Sale bind every customer and partner to anti-bribery, anti-slavery, export-control and ethical-conduct obligations as a condition of doing business with Euro Biom.
• Employee and Worker Protections: all Euro Biom staff are employed under UK employment law with documented contracts, fair wages, and clear terms of engagement. We do not use agency workers, zero-hours contracts, or any form of labour arrangement that could obscure the employment relationship.
• Whistleblowing: any member of our team or any external party who suspects modern slavery or unethical labour practices within our operations or supply chain can report concerns directly to the company director without fear of retaliation.

4. Risk Assessment

We have assessed our operations and supply chains for modern slavery risk and consider our overall risk level to be low, for the following reasons:

• Our pharmaceutical suppliers are regulated entities operating under UK manufacturing, marketing or distribution authorisations, subject to inspection by the MHRA.
• Our team is small, directly employed, and UK-based. We do not outsource labour or use temporary staffing agencies.
• We use specialist pharmaceutical freight providers and seek documented agreements and GDP-compliant quality systems from each one.
• We do not operate in sectors commonly associated with high modern slavery risk, such as agriculture, textiles, construction, or domestic services.

We recognise that the international nature of pharmaceutical supply chains means risks can evolve. Where we expand into new markets or engage new partners, we will conduct specific risk assessments appropriate to those relationships.

5. Training and Awareness

All Euro Biom staff receive guidance on modern slavery awareness as part of their compliance induction. This includes understanding the indicators of forced labour, debt bondage, and human trafficking, and knowing how to escalate concerns through the appropriate channels.

As a small team, we have direct oversight of all business relationships and can monitor for any emerging concerns in real time. The company director is responsible for ensuring our supply chain remains transparent and ethically managed.

6. Effectiveness and Review

We measure the effectiveness of our approach through the following indicators:

• Completion of supplier qualification checks for all pharmaceutical supply partners
• Any reports of modern slavery are investigated and recorded
• Annual review and update of this statement
• Staff awareness confirmed through compliance training records

This statement will be reviewed and updated annually, or sooner if there is a material change in our business operations, supply chain, or risk profile.

7. Status of This Statement

This is a voluntary statement published by Euro Biom Ltd.

8. Contact

If you have any questions about this statement or wish to report a concern, please contact us at work@eurobiom.co.uk.