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Modern Slavery Statement


Introduction

Alliance Pharma Ltd and its subsidiaries (“Alliance” / “We” / “Our” / “Group”) is committed to actively implementing actions and due diligence processes aimed at preventing the presence of modern slavery or human trafficking in any part of our business, including our supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Alliance’s slavery and human trafficking statement for the financial year ending 31 December 2025.

Our Business Structure and Supply Chains

We are a consumer healthcare company with the purpose of empowering people to make a positive difference to their health and wellbeing by making our trusted and proven brands available around the world.

We deliver organic growth through investing in our priority brands and channels, in related innovation, and through selective geographic expansion to increase the reach of our brands. Periodically, we may look to enhance our organic growth through selective, complementary acquisitions.

Headquartered in the UK, the Group employs around 290 people across Europe, North America, and the Asia Pacific region. Our business model is predominantly built on outsourcing manufacturing and distribution.

On 14 May 2025 Alliance Pharma PLC Group was purchased by DBAY Partners and was delisted from the AIM market of the London Stock Exchange. Alliance became a private company and changed its name to be Alliance Pharma Ltd.

Alliance has operating affiliates incorporated in the UK, mainland Europe, China, Singapore, Thailand, the Philippines, and the USA.

Our supply chains include:

  • Raw material/API suppliers
  • Componentry suppliers
  • Contract manufacturers
  • Freight forwarders
  • Warehouse storage

Most of our components are sourced in Europe (circa 64%), the USA (circa. 16%), while around 20% are supplied by manufacturers and suppliers in China and South-East Asia.

As part of a broader value chain, our products reach customers through retail, e-commerce, healthcare providers, and distributors.

Supply Chain Understanding

Alliance recognises that visibility is limited beyond tier 1 suppliers. Future improvements will therefore include carrying out enhanced risk assessments to identify weaknesses in lower tiers.

Products, Sectors and Services

We operate in the healthcare and consumer goods sectors. Our main products include pharmaceutical and cosmetics.

Direct and Indirect Suppliers

Our direct suppliers include raw material/API suppliers, componentry suppliers, contract manufacturers (pharmaceutical, healthcare, cosmetics), warehouse providers, and logistics partners.

Our indirect suppliers provide a broad range of goods and services supporting our business operations. These include key categories such as IT & Digital, Facilities Management, Professional Services, Marketing, Consultancy, and Logistics & Distribution. They are primarily based in the UK, Europe, North America, and Asia-Pacific, and operate across diverse industries including technology, facilities and maintenance, business and financial services, marketing and communications, and global logistics.

Modern Slavery Risk Management Governance and Information Gathering

We are committed to taking every possible measure to prevent modern slavery or human trafficking in any part of our business including our supply chains. Our anti-slavery initiatives align to our corporate behaviour of leading with courage and humility and our sustainability commitment of conducting business responsibly.

To enact our commitment, the overall responsibility for the anti-slavery and labour exploitation programme sits with the legal team, and overall accountability sits with the General Counsel and Company Secretary. The Head of Legal oversees policies and employee training relating to addressing modern slavery and feeds information to the General Counsel and Company Secretary who shares information with the Board.

Our policies on slavery and human trafficking

Internal Operating Policies

In keeping with our ‘5 To Drive Behaviours’ (Act with Impact, Lead with Courage and Humility, Create New Possibilities, Consumer at the Heart and Win Together), we maintain a suite of policies which support preventing, identifying and addressing modern slavery and trafficking in our operations and supply chain. We continually review and develop our policies with input from in-house experts, suppliers and external specialists. Our key policies include:

Our Anti-Slavery Policy reflects our commitment to acting ethically in all our business relationships and to continuing to work to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. The policy sets out clear roles and responsibilities of our employees and suppliers and provides an escalation procedure for them to raise concerns and issues.

Our Employee Code of Conduct sets out the behavioural standards expected from all individuals when representing Alliance. The Code includes a section on the detection and prevention of modern slavery. The guidelines detailed in the Code apply to all Alliance personnel, whether permanent or on fixed term contracts and includes agency workers, contractors and directors.

Our Partner Code of Conduct is applicable to all external contracting parties providing goods and services to Alliance (including our distributors) and makes explicit reference to Alliance’s expectations around the detection and prevention of modern slavery in our partners’ workplaces and supply chains. Our Code encourages a culture of openness between Alliance and our partners, and we enable small-sized partners to adopt the Code, where otherwise they may not have the capacity to develop their own.

Under Alliance’s Anti-Bribery and Corruption Policy we see Alliance commit to the highest standards of ethical conduct and integrity in our business activities in the UK and overseas and this commitment is set out in the organisation’s Anti-Bribery and Corruption Policy. Alliance has a zero-tolerance approach to any form of bribery by our employees, agents or consultants or any other person or body acting on our behalf.

Our Speak-Up Policy offers all employees and contractors a confidential process through which concerns can be raised within the organisation in the knowledge that they will be taken seriously and dealt with in an appropriate and professional manner. In 2022, Alliance partnered with Safecall, an independent third-party helpline, to enable employees, partners, and the public to report (including on an anonymous basis) any concerns about Alliance’s practices, including any modern slavery concerns.

Stakeholder Engagement (Policy Development)

Our policy development has involved in-house experts and often involves external collaboration with organisations such as Slave-Free Alliance.

Communication and Enforcement

Policies are communicated internally through the company intranet, which is accessible to all employees. They are also covered during legal induction training, and employees complete annual online training on key compliance topics, during which they are required to read and acknowledge the relevant policies. Our policies are communicated externally to our contract manufacturing organisations (CMOs) through our sourcing platforms. The Partner Code of Conduct is shared with all our contract manufacturing organizations and key distribution partners to ensure alignment with our standards and expectations.

Key risks

It is estimated that nearly 50 million people globally are trapped in some form of modern slavery on any given day[1]. In view of this, Alliance recognises that modern slavery and labour exploitation risks are ever evolving and is alert to the current external factors that can increase vulnerability, such as high global inflation, war and conflict, disasters and climate change. Alliance has therefore identified the areas of our value chains that are at risk of modern slavery and labour exploitation and will continue to monitor and enhance our risk management controls in the following ways,

Risk Assessment Frequency and Risk Assessment Governance

We have worked with Slave Free Alliance to carry out a review of our Modern Slavery compliance and have been working to action points identified.

Identifying and Assessing Risks

As part of our initiative to identify and mitigate risk we have in place systems, including the use of external due diligence advisers and certain software platforms, to:

  • Identify and assess potential risk areas in our supply chains.
  • Monitor the risk of slavery and human trafficking occurring in our supply chains by engaging with suppliers committed to rejecting modern slavery and upholding human rights.
  • Monitor potential risk areas in our supply chains by conducting audits during site visits and by investigating any concerns identified in the course of business.
  • Protect whistleblowers by providing a Speak Up line which is a third party provider who employees and suppliers can raise any concerns anonymously.

Highest Priority Risks to Workers

The highest priority risks identified relate to CMOs, warehousing and logistics roles, raw materials and mineral sourcing, and outsourced goods and services such as cleaning and maintenance. These are explained further below.

  • Contract Manufacturing Organisations (CMOs): Our CMOs are our strategic partners that play a key role in the production of our products. Elements such as cleaning and changeover operations, operational geographies and the multiple production sites used to prevent contamination limit our visibility of employment practices and are vulnerable to the risk of exploitation. Alliance is in regular contact with its CMOs and conducts thorough on-site audits, so we are well placed to observe and monitor worker welfare.
  • Warehousing and logistics: Warehouses and logistics activities in the pharmaceutical industry are more technical and require higher skill sets than traditional warehousing and logistic operations. However, roles such as warehouse pickers, cleaners, and lorry drivers are still high-risk to modern slavery and labour exploitation. High turnover rates and industry demand upon these parties and subsequent labour agencies to provide workers at short notice puts a strain on them to source workers quickly and cheaply, leaving them susceptible to trafficker low-rate offerings.
  • Raw materials and minerals: Sourcing activities for the primary materials and mineral necessary for the composition of pharmaceutical and cosmetic products are high-risk to modern slavery and labour exploitation. Many of the raw materials are sourced in countries where child labour, irregular to non-payment of wages, and bonded labour are common types of exploitation. These sourcing activities sit in the lowest tiers of our supply chain and Alliance plans to carry out a risk assessment to gain further visibility of our raw material and sourcing activity. Once we have further developed our anti-slavery and labour exploitation programme and supplier engagement on this matter, we intend to call on brands and suppliers to use our collective leverage and collaborate in this area to affect positive change.
  • Outsourced goods and services: Alliance also recognises the increased risk of modern slavery and labour exploitation in our outsourced services of cleaning, maintenance and security. We also employ local workers to minimise the risk of workers travelling from afar.

Continuous Improvement (Risk Assessment)

In 2026, Alliance will continue to take a proactive approach to modern slavery, focusing on enhanced training, such as expanding our modern slavery training to include targeted sessions for high-risk roles such as procurement, and introducing refresher training for existing staff. Alliance will continue to carry out audits on our suppliers, to deepen supplier engagement and to ensure ethical practices in high-risk areas.

Due Diligence

Prevention and Mitigation

All Alliance’s pharmaceutical products (and their components) comply with Good Manufacturing Practice (GMP) rules. To be GMP compliant, manufacturers must follow strict rules regarding the quality of (a) products they produce, (b) their facilities and (c) their employees.

Alliance itself carries out regular site visits and compliance (including modern slavery) checks on our manufacturers and their facilities. These are in addition to periodic inspections (on a risk assessment basis) by government regulators to check they are GMP compliant, including regular site visits to sites of our direct supplier for both auditing and relationship purposes.

In 2025, we conducted between 6-10 in-person site visits to our key CMOs and after each visit our team completed Alliance’s modern slavery questionnaire with no human rights concerns raised. We will continue to conduct modern slavery audits of our top strategic supplier base in 2026.

For our healthcare products, Alliance has an on-boarding process through which potential suppliers are vetted by our financial, commercial and quality teams. This includes members of the Alliance team completing modern slavery due diligence questionnaires and Alliance’s quality team carry out site audits. Alliance requires all of our suppliers to comply with ISO 13485; 2016, and Medical Device Distribution Standards. We are currently working towards being ready for full compliance with the Medical Device Regulations. For our cosmetics, Alliance requires full compliance with ISO 22716.

In the USA, Alliance adheres to USA21CFR800 and for foods in the USA we require compliance with USA21CFR100.

These standards include adhering to labour laws and ethical practices, such as the prevention of modern slavery and human trafficking.

Supplier adherence to our values and ethics

In addition to our Partner Code of Conduct, all of Alliance’s new supplier contracts include applicable Modern Slavery Act warranties and undertakings. We demand that all new suppliers acknowledge their responsibilities to operate in a manner that is free from modern slavery and human trafficking practices.

Grievance Mechanisms and Remediation Policies and Processes

No slavery or human trafficking issues were identified during the reporting period, and no reports were made under relevant policies. However, in the event that Alliance was to have any concerns related to our partners (whether this be distributors, suppliers or otherwise) we would, in the first instance, seek to understand and resolve these concerns and drive continuous improvement (with the welfare of the victim(s) as the primary basis of any corrective action). If we were unable to do so, we would responsibly exit from the partner as a last resort.

As stated in our policies section, the Speak-Up Policy and Safecall helpline provide confidential reporting for employees, contractors, and the public.

Training

Internal and external training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide mandatory modern slavery awareness training to all our employees at induction and as annual refresher training.

Annual e-learning training is provided to assist with the understanding and identification of modern slavery and human trafficking. Our training strategy also includes that we provide enhanced training to teams that have a close interaction with risk areas.

In 2025, we started to develop a bespoke modern slavery in procurement workshop with Slave-Free Alliance for our team in China.

Our effectiveness in combating slavery and human trafficking

We continue to monitor and assess the appropriateness of the use various key performance indicators (KPIs) to measure how effective we are and have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.

Goal setting

Our goals for the next year include:

  • Developing a vetting and screening process for third-party suppliers/partners at the time of onboarding.
  • Ongoing monitoring on a risk-based approach as part of the further development of our processes.
  • Subcontractor inspections both on an ad-hoc and scheduled basis.
  • Speak-Up procedures being widely communicated and effectively implemented.
  • General awareness training to all employees and targeted training to relevant employees in key functions.
  • Remedial action if any issues are identified.

Stakeholder Engagement

Collaboration

Our yearly actions and progress have been supported by engagement with suppliers, logistics partners as well as organisations and human rights initiatives.

In 2022, Alliance entered a three year partnership with Slave-Free Alliance, a social enterprise wholly owned by global anti-slavery charity Hope for Justice, which works with businesses to increase their resilience to modern slavery and labour exploitation in their operations and supply chains.

Also, Alliance continued its participation as a member of the UN Global Compact, officially joining in August 2024. We submitted our first Communication on Progress (COP) in July 2025.

Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31 December 2025. It was approved by the Directors of Alliance Pharma Ltd on 23 December 2025.

Nick Sedgwick
Chief Executive Officer
23 December 2025