Introduction
This statement is made pursuant to the Modern Slavery Act and constitutes Samphire Neuroscience Limited's modern slavery and human trafficking statement. It sets out the steps we have taken to ensure that modern slavery and human trafficking are not taking place in our business or supply chains.
Samphire Neuroscience takes a zero-tolerance approach to modern slavery in all its forms, including forced labor, child labor, debt bondage, and human trafficking. We are committed to acting with integrity and transparency in everything we do.
Our organization and supply chains
Samphire Neuroscience is a UK-registered neurotechnology company developing brain-based wearable devices and digital health products to support women's health. We are headquartered in the United Kingdom and supply products to customers in the United Kingdom, European Union, and internationally. Samphire Group is a US-registered neurotechnology company with similar activities to Samphire Neuroscience.
Our supply chain encompasses:
- Hardware manufacturing — electronic component sourcing and device assembly, primarily through specialist contract manufacturers
- Packaging and fulfillment — third-party logistics and fulfillment partners operating across the world
- Software and services — software development and cloud infrastructure services provided by established technology companies
- Professional services — legal, regulatory, and advisory services sourced from across the world
We work with a limited number of carefully selected suppliers. Our direct supply chain is relatively small, which allows us to maintain closer oversight of the businesses we work with.
Our policies
We maintain a number of policies that reflect our commitment to acting ethically and with integrity:
- Code of Conduct — setting out the standards of behavior we expect from all employees, contractors, and business partners, including compliance with applicable laws on labor rights and human rights
- Supplier Due Diligence Policy — requiring suppliers to confirm compliance with the Modern Slavery Act and applicable labor laws before we enter into or renew commercial relationships
- Recruitment Policy — ensuring all recruitment is conducted lawfully, including right-to-work verification, and that we never use unlicensed labor providers
Due diligence processes
We conduct due diligence on our supply chain on an ongoing basis. Our processes include:
- Pre-engagement screening — before entering a new supplier relationship, we assess suppliers' practices and require written confirmation of their compliance with the Modern Slavery Act 2015 and relevant labor laws
- Contractual protections — our supplier agreements include provisions requiring compliance with applicable anti-slavery and human rights legislation, and the right for us to audit suppliers' labor practices
- Annual review — we review key supplier relationships annually, including reassessing modern slavery risk where supply chains or geographies change
- Escalation process — where concerns about modern slavery are identified, we have a clear escalation path to senior management and, where appropriate, to law enforcement authorities
Risk assessment
We assess and manage modern slavery risk across two areas:
Direct operations: We consider the risk in our direct operations to be low. We are a small business employing a professional workforce, operating in a highly regulated sector. All staff are employed on lawful, transparent contracts and remunerated at or above the National Living Wage.
Supply chain: We recognize that greater risks may exist further along our supply chain — particularly in the manufacture of electronic components, where global supply chains can be complex and span higher-risk jurisdictions. We focus our due diligence efforts accordingly and continue to develop our understanding of these risks as our business grows.
We will continue to refine our risk assessment approach as our business and supply chain evolve.
Key performance indicators
To assess the effectiveness of the steps we are taking, we monitor the following:
- Percentage of new suppliers who have signed our supplier code of conduct or provided equivalent written confirmation of compliance
- Number of supplier audits or reviews completed per year
- Staff awareness of our modern slavery policy and reporting process
In the current period, no reports of suspected modern slavery were made through our whistleblowing or reporting channels.
Training and awareness
We provide information and guidance to employees on identifying and reporting modern slavery. All new employees are made aware of our Code of Conduct during onboarding. We will continue to develop targeted training as our business grows and as best practice guidance evolves.
How to report a concern
If you believe that modern slavery or human trafficking is occurring within our business or supply chain, please report this immediately to us at support@samphireneuro.com (mailto:support@samphireneuro.com). We will investigate all concerns raised and take appropriate action.
You may also report concerns directly to the Modern Slavery Helpline on 0800 0121 700 or via the Modern Slavery Helpline website.
Approval and review
This statement was approved by the Board of Directors of Samphire Neuroscience. It will be reviewed and updated annually.