Modern Slavery and Human Trafficking Policy and Annual Statement 2026/27

1. Our commitment

Gold Standard Phantoms Limited does not tolerate modern slavery or human trafficking in any part of our business or our supply chain. We are committed to acting ethically and with integrity in all our business relationships, and to putting in place effective systems and controls to make sure modern slavery is not taking place anywhere in our own business or in any organisation that supplies us.

We recognise that our responsibility does not end at our own front door. As a manufacturer sourcing components and materials internationally, we accept that we must understand and manage the risk that exists further down our supply chain, and that this requires continuous improvement rather than a one-off exercise.

Statutory position. Section 54 of the Modern Slavery Act 2015 requires organisations with an annual turnover of £36 million or more to publish an annual slavery and human trafficking statement. Our turnover is below this threshold, so we are not legally required to publish a statement. We have adopted this policy voluntarily because it reflects our values and because our customers, including NHS organisations and academic institutions, are entitled to assurance about the conditions in which our products are made.

2. Purpose and scope

This policy sets out what we do to prevent modern slavery and human trafficking, who is responsible for each part of that work, and what we expect of everyone who works for us or with us.

It applies to all individuals working for the company or on our behalf in any capacity, including employees at all levels, directors, agency workers, contractors, consultants and any other third-party representative. We also expect our suppliers, and their own suppliers, to meet the standards set out in section 6, Our supply chain.

Statement period

This document constitutes Gold Standard Phantoms Limited's Modern Slavery and Human Trafficking Policy and its voluntary Modern Slavery Statement for the financial year ended 31 December 2027. It describes the policies and controls we maintain and the steps taken during that financial year to identify, prevent and mitigate modern slavery and human trafficking risks in our business and supply chain.

3. What we mean by modern slavery

Modern slavery is a criminal offence under the Modern Slavery Act 2015. It covers slavery, servitude, forced or compulsory labour, and human trafficking. In a business setting it can be less obvious than the term suggests, and may appear as:

• workers who have had their passport or identity documents taken from them;
• workers who have paid a fee to secure their job, or who are working to repay a debt to a recruiter or employer;
• wages paid into an account controlled by somebody else, or unexplained deductions from pay;
• excessive hours, or workers who appear unable to leave their employment or accommodation freely;
• a third party speaking on a worker's behalf, or several workers sharing a single address or bank account;
• signs of fear, withdrawal, physical injury, or a reluctance to talk about living arrangements.

Modern slavery is more likely to be found in low-skilled, temporary or agency labour, in cleaning, catering, logistics, security and construction, and in the extraction and manufacture of raw materials and electronic components overseas.

4. Responsibilities

Responsibility for this policy is shared. The Board is accountable overall, while HR and Operations each own the parts closest to their work.

5. Our people

Our direct workforce is based in Sheffield and is a low-risk population: our roles are skilled, permanent and salaried, and we recruit and employ directly. We nonetheless maintain the following controls.

• We verify the right to work in the UK of every new starter before employment begins, and we keep compliant records of those checks.
• Every employee and worker receives a written statement of employment particulars, is paid at least the National Living Wage or National Minimum Wage appropriate to their age and is paid directly into a bank account in their own name.
• We never charge any worker a fee, of any kind, to obtain or keep a job with us.
• We never hold a worker's passport, identity documents or personal papers. Where documents are checked, they are returned immediately.
• We comply with the Working Time Regulations 1998. Overtime is voluntary.
• Every worker is free to leave their employment on notice, and free to join a trade union.
• Where we use agency, temporary or contract labour, we use only reputable employment agencies, and we satisfy ourselves that the agency is licensed where a license is required and that it applies standards equivalent to our own.
• We prohibit child labour, forced or compulsory labour, threats or intimidation, workplace discrimination connected with exploitation, and any restriction on workers' freedom of movement.

6. Our supply chain

We design and manufacture precision imaging phantoms in Sheffield. Our supply chain includes machined and moulded components, electronic and electrical parts, chemicals and fluids, packaging, calibration and laboratory services, and international freight. We accept that the further we look beyond our immediate suppliers, the less visibility we currently have, and reducing that gap is a priority for the coming year.

During the reporting period, Gold Standard Phantoms Limited operated from one UK location, employed approximately 9 people and purchased goods and services from approximately 20 active suppliers.

Our direct operations are based in Sheffield, UK. Our supply chain extends internationally and includes suppliers of machined and moulded components, electronic and electrical components, chemicals and fluids, packaging, calibration and laboratory services, and freight/logistics services. During the reporting period, our suppliers were principally located in UK, Europe and USA.

Risk assessment

We assess modern slavery risk using a risk-based approach, considering factors including:

• country/geographical risk;
• nature of the goods or services supplied;
• use of low-skilled, temporary, migrant or agency labour;
• labour-intensive manufacturing processes;
• complexity and visibility of the supply chain;
• use of subcontracting;
• known sector or commodity risks; and
• information received from suppliers or other credible sources.

Priority risks during 2026/27

Our assessment identified that our greatest potential exposure to modern slavery is within the extended supply chain rather than our directly employed workforce. Particular areas of focus are:

• electronic and electrical components manufactured through multi-tier international supply chains;
• raw materials and manufactured components sourced from countries or sectors with elevated labour-rights risks; and
• outsourced services where temporary, agency, migrant or lower-skilled labour may be used, including logistics.

Due diligence

• We maintain a record of our suppliers and the goods or services they provide, and we keep this under review.
• New suppliers are asked, as part of onboarding, to confirm that they comply with the Modern Slavery Act 2015 and that they hold equivalent standards in their own supply chain. Where a supplier is required to publish a modern slavery statement, we ask to see it.
• Our standard purchase terms require suppliers to comply with all applicable modern slavery and employment legislation, and to notify us promptly if they identify a problem.
• We assess suppliers for risk according to the nature of what they supply and the country it comes from, and we focus our attention on those we judge to carry the greater risk rather than spreading it thinly across all of them.
• Where we identify a credible concern about a supplier, our first response is to work with them to put it right and to protect the workers affected. We will end a business relationship where a supplier will not engage or will not improve.

Where modern slavery is identified, our response will prioritise the safety, rights and interests of affected workers. Depending on the circumstances, remediation may include requiring corrective action from a supplier, supporting repayment of unlawfully charged recruitment fees or withheld wages, facilitating access to appropriate support, working with relevant authorities or specialist organisations, and monitoring corrective action. Termination will be considered where a supplier refuses or fails to remediate the issue, taking account of the potential impact on affected workers.

7. Training and awareness

• All new employees receive an introduction to this policy as part of induction, covering what modern slavery looks like in practice and how to raise a concern.
• Staff in roles with greater exposure — those involved in recruitment, purchasing, supplier management and logistics — receive further, role-specific training.
• This policy is available to all staff on MyHRToolkit and is held with our other governance documents on Seafile.
• We keep a record of who has completed training and when.

8. Raising a concern

Anyone who suspects that modern slavery is taking place, whether in our business or in our supply chain, must report it. You will not suffer any detriment for raising a concern honestly, even if it turns out to be mistaken.

Concerns should be raised with your line manager, or with the HR contact at hr@goldstandardphantoms.com, or with Xavier Golay, CEO where you would rather not go through your manager.

Suspected modern slavery can also be reported directly to the Modern Slavery and Exploitation Helpline on 08000 121 700, or to the police on 101. If someone is in immediate danger, call 999. Every report is taken seriously, recorded, and investigated. Where there is a credible suspicion of a criminal offence, we will report it to the appropriate authority.

9. Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with any individual, organisation or supplier that breaches it.

10. Monitoring and review

• HR and Operations jointly review this policy at least annually and report to the Board on its operation.
• As part of that review we consider: the number of concerns raised and how they were resolved, the proportion of new suppliers who have given a modern slavery declaration, and the proportion of staff who have completed training.
• We will keep our position under review if our turnover approaches the £36 million threshold at which a published statement becomes a legal requirement.
• We complete the Modern Slavery Assessment Tool (MSAT) where a customer requires it, and we act on the recommendations it produces.

Annual KPIs

Priorities for 2026/27

During the reporting period we intend to:

• complete risk categorisation of all active suppliers;
• increase visibility beyond Tier 1 for identified higher-risk supply chains;
• obtain modern slavery declarations from 100% of new suppliers;
• review statements of suppliers legally required to publish one;
• complete role-specific training for all relevant procurement, logistics and HR staff;
• review the effectiveness of our supplier due-diligence process; and
• review our MSAT assessment and implement appropriate recommendations.