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Responsibility

Modern Slavery Policy

Modern Slavery and Human Trafficking Statement 2026, prepared with reference to the Modern Slavery Act 2015.

Our position

Our commitment

Oranda Therapeutics Limited (“Oranda”) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chains. We recognise our responsibility to tackle this issue proactively and to take a robust approach through our internal policies and supply chain due diligence.

This first statement has been prepared voluntarily, with reference to section 54 of the Modern Slavery Act 2015, and in support of NHS procurement, investor, and stakeholder expectations. It sets out actions to understand all potential modern slavery risks related to our business and to put in place steps aimed at ensuring that there is no slavery or human trafficking in our own business or our supply chains.

As Oranda grows, it intends to strengthen its policies, supplier due diligence processes and monitoring arrangements proportionately and practically, reflecting the nature, scale and maturity of the organisation.

As Oranda grows, we want responsible business practice to be built in from the start. Our purpose is to improve access to rare disease medicines, and that responsibility extends to how we work with partners, manage our supply chain and uphold human rights.

John Irwin CCO & Co-Founder, Oranda Therapeutics
Summary

At a glance

A summary of our operating model, governance approach, supply chain and commitment to continuous improvement.

Small, remote-first team

Limited direct operational footprint and no directly controlled manufacturing, warehousing or laboratory assets.

Key supply chain

Our manufacturing and distribution partners operate in accordance with applicable regulatory requirements.

Board-level supplier approval

Supplier approval is overseen at Board level, supporting accountability for responsible supply-chain governance.

First-year statement

This is Oranda's first modern slavery statement and establishes the baseline for future improvement, supported by a 12-month plan to strengthen supplier due diligence, controls and review.

Our business and operating model

Oranda is a rare-disease pharmaceutical company focused on improving patient access to affordable rare disease medicines. Oranda is in the early stages of operational development. It currently operates through a lean organisational model, with a small team and a predominantly remote-working structure.

Oranda’s business model relies on specialist third-party partners for key elements of pharmaceutical manufacture, testing, release, logistics, warehousing and distribution. This makes responsible supplier selection, oversight and governance important areas of focus for Oranda’s modern slavery and wider ESG approach.

Our supply chain

Oranda operates in a highly regulated pharmaceutical environment. Manufacturing and distribution partners are expected to operate in accordance with applicable regulatory requirements, including EMA, MHRA, Good Manufacturing Practice and Good Distribution Practice standards where relevant. These controls support supply chain governance, quality and patient safety.

Oranda recognises, however, that modern slavery, human rights and labour standards require specific and proportionate due diligence alongside regulatory compliance.

  1. 01 Active Pharmaceutical Ingredient suppliers
  2. 02 Contract Manufacturing Organisations
  3. 03 Quality release and regulatory partners
  4. 04 Stockholding and distribution partners
  5. 05 Logistics partners
  6. 06 Healthcare system supply
Risk

Where the risk sits

Modern slavery risk is currently greatest in outsourced supply chain activities, rather than Oranda's direct operations.

Low direct operational risk

Direct workforce

Contractors (UK & EU)

Medium supply-chain focus

Third-party manufacturing

Non-European supply chain partners

Visibility to improve

Lower-tier suppliers

Subcontracted labour and supplier recruitment practices

Risk assessment detail

Modern slavery risk assessment by area, with the current view, the reasoning behind it and the action planned.
Area Current view Why Action
Direct workforce Low Small, skilled, remote-first team Maintain ethical employment practices
Contractors (UK & EU) Low Professional services support Include expectations in contractor terms
Manufacturing Medium Third-party manufacture outside the UK/EU Request supplier labour and ESG information proportionally from higher-risk suppliers
Logistics / warehousing Medium Third-party stockholding and distribution Review policies and contractual controls
Lower-tier suppliers To be reviewed Limited current visibility beyond direct partners Improve supplier mapping

Oranda's direct operational risk is currently low, while the priority is strengthening visibility and controls across key supply chain partners.

Process

Our due diligence process

Oranda will apply supplier due diligence proportionately, prioritising higher-value, higher-risk and business-critical supplier relationships, particularly those involving manufacturing, distribution, logistics, stockholding or non-European supply chain activity. Oranda's current and proposed due diligence activities include the following steps:

  1. 1
    Identify

    Supplier register

    Confirm key suppliers and their role in the supply chain.

  2. 2
    Prioritise

    Risk rating

    Rate suppliers by geography, activity and importance to supply.

  3. 3
    Request

    Supplier questionnaire

    Where relevant, ask for modern slavery, labour, ESG and governance information.

  4. 4
    Review

    Due diligence record

    Review responses and identify gaps.

  5. 5
    Engage & improve

    Improvement notes

    Discuss gaps, agree on proportionate next steps and review over time.

Supplier contract controls

For new supplier contracts and contract renewals, Oranda will seek to include appropriate modern slavery, ethical business and responsible labour expectations where relevant and proportionate.

For existing contracts, Oranda may seek non-contractual alignment through supplier expectations, codes of conduct, policy sharing or supplier engagement where appropriate.

Where gaps or concerns are identified, Oranda will seek to understand the issue and engage with the supplier on proportionate next steps. Any response will take into account patient access, product quality, and continuity of medicines supply. Serious or unresolved concerns may be escalated to senior leadership or the Board.

Policy controls

A proportionate governance stack for Oranda's modern slavery and ESG approach.

In place
  • Board oversight
  • Modern Slavery Statement
  • ESG Policy
In development
  • Supplier Due Diligence Process
  • Supplier Code of Conduct / Supplier Expectations
To be embedded
  • Contract clauses
  • Training and awareness
  • Reporting and escalation

Training, awareness and reporting concerns

Oranda will provide proportionate modern slavery and ESG awareness to the Board, employees, consultants and contractors involved in supplier selection, supplier management, procurement, regulatory activity and ESG matters. As the organisation grows, training will be reviewed and developed to reflect Oranda’s operating model, supply chain and risk profile.

Oranda will encourage concerns relating to modern slavery, human trafficking, labour standards or unethical supplier conduct to be raised with senior leadership or the Board. As Oranda develops its ESG and supplier governance framework, it will confirm appropriate reporting and escalation arrangements.

Measuring effectiveness

Given Oranda's current stage of development, this statement establishes an initial baseline for modern slavery and supply chain governance. Oranda will review the effectiveness of its approach annually. Initial indicators include:

Modern slavery effectiveness indicators, with the 2026 baseline and the 12-month aim for each.
Indicator 2026 baseline 12-month aim
Key direct suppliers identified Initial direct suppliers known Maintain supplier register
ESG / supplier due diligence owner assigned To be confirmed Confirm owner
Supplier expectations developed Not yet in place Develop and consider sharing with priority suppliers where relevant
Modern Slavery Statement reviewed by Board Initial statement Annual Board review
Supplier due diligence approach Developing Develop proportionate approach for higher-value, higher-risk or business-critical suppliers
Next 12 months

12-month improvement plan

Over the next 12 months, Oranda intends to:

  1. 1

    Approve statement and confirm ESG / supplier due diligence owner

    0 to 3 months

    Output: Board-approved statement and named owner

  2. 2

    Maintain a register of priority suppliers and develop supplier expectations

    0 to 6 months

    Output: Supplier register and supplier expectations document

  3. 3

    Share expectations with priority suppliers where relevant and proportionate

    6 to 12 months

    Output: Supplier engagement record

  4. 4

    Review progress and update statement

    12 months

    Output: Annual Board review and 2027 statement

Closing statement

At the date of this statement, Oranda is not aware of any modern slavery or human trafficking concerns within its direct operations or known supply chain.

Oranda recognises that modern slavery risk can be hidden and will continue to strengthen its approach as the business grows.

If Oranda identifies an actual or suspected modern slavery concern, it will seek to understand the issue, protect affected individuals where relevant, engage with the supplier, and agree on appropriate corrective actions.

Oranda will avoid abrupt action that could worsen harm to workers, while reserving the right to escalate, suspend or terminate supplier relationships where serious or unresolved concerns remain.

Board approval

This statement has been approved by the Board of Directors of Oranda Therapeutics Limited and will be reviewed annually.

OTD-NP-GBR-00049 | August 2026