Modern Slavery constitutes a severe violation of human rights and stands as a criminal offense under the Australian Modern Slavery Act 2018. The Act enumerates eight forms of severe exploitation that are encompassed within the scope of Modern Slavery:

• Trafficking in persons
• Slavery
• Servitude
• Forced marriage
• Forced labour
• Debt bondage
• Deceptive recruiting for labour or services
• Worst forms of child labour, involving situations where children are subjected to practices akin to slavery or engaged in hazardous labour.

1. Purpose

This policy is designed to achieve several critical objectives:

• Proactively prevent, detect, and respond to potential Modern Slavery risks within the operations of Blueprint Medical (the Company), its supply chain, and all business relationships.
• Demonstrate the Company’s unwavering commitment to exclusively engage with entities fully compliant with the Act.
• Ensure strict adherence to the Act’s provisions, including any potential future amendments.

2. Scope

This policy applies to all individuals collaborating with or working within the Company in any capacity. This encompasses employees, directors, officers, volunteers, interns, external consultants, third-party representatives, and business partners.

3. Policy Statement

Blueprint Medical maintains a zero-tolerance stance towards Modern Slavery. We are dedicated to upholding ethical conduct and integrity in all our business interactions and affiliations. We will establish and enforce robust systems and controls to eradicate any trace of Modern Slavery from our business operations and across our supply chains. Our commitment to transparency aligns with our disclosure obligations under the Act.

Every individual associated with the Company, directly or indirectly, shares the responsibility of preventing, identifying, and reporting instances of Modern Slavery. Employees, including contractors, are strongly encouraged to promptly report any suspicions of Modern Slavery breaches within the Company’s supply chains to their respective managers or the Director of Governance.

Contractors, suppliers, and other business partners engaged with the Company will be held to the same rigorous standards. Our contractual agreements will explicitly prohibit the use of forced, compulsory, or trafficked labour, as well as any form of slavery or servitude. We also expect our partners to extend these standards to their own suppliers.

4. Modern Slavery Program

A. Policies

The Company currently enforces the following policies, which foster awareness of acceptable practices, provide reporting mechanisms, and promote ethical behaviour:

• Complaints Policy
• Non-conformance and Corrective Action Procedure
• Employee Code of Conduct.

B. The Information We Collect

1. Procurement of Goods and Services (Procurement Policy and Procedure): Our procurement process places due diligence at its core, evaluating suppliers’ adherence to the Act’s requirements. Depending on the nature of goods or services, due diligence may encompass requesting:

• Supplier self-assessment of Act compliance
• The supplier’s latest Modern Slavery statement (if applicable)
• Insights into the structure and operations of their supply chain
• Details of their measures to address modern slavery risks Our contracts will include provisions to ensure compliance with the Act.

2. Management and Monitoring of Key Suppliers/Partners: Our contracts will incorporate anti-slavery clauses, mandating compliance with the Act. These clauses encompass obligations to:

• Adhere to the Act
• Prevent modern slavery within supply chains.
• Report any breach to the Company
• We will collaborate closely with vital partners to identify and mitigate modern slavery risks

3. Statement Preparation, Endorsement, and Approval: The Act mandates annual compliance statements for entities with revenue exceeding $100 million. These statements, endorsed by the Board and relevant authorities, affirm our commitment to preventing Modern Slavery.

5. Conclusion

Blueprint Medical remains steadfast in its dedication to eradicating Modern Slavery. This policy reinforces our commitment to ethical conduct, human rights, and social responsibility. Through these actions, we pledge our allegiance to the well-being of the communities we serve and the values we uphold.

Records Management

The Modern Slavery Policy is a Level 1 Governance Policy. The latest approved version of the Modern Slavery Policy will be stored on the Policy Bank on the BPM intranet (Bright HR) and the share drive.

The policy owner will maintain a record of issues relevant to the Modern Slavery Policy for consideration at the time of review.

Legislation and Standards

Modern Slavery Act (COM) 2018

Australian Charities and Not for profit Commission (ACNC) – External Conduct Standards