Modern Slavery Act Statement 2022

This statement is published pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 (the “Act”) on behalf of ELLKAY International Limited (“ELLKAY”). This statement describes the actions and activities ELLKAY has taken to ensure that slavery and human trafficking is not taking place in ELLKAY supply chains or in any part of ELLKAY business. ELLKAY is committed to acting ethically and with integrity in its business operations and supply chains.

BUSINESS AND ORGANIZATION

ELLKAY is a private limited company incorporated in England and Wales under number 14078392 and wholly owned by ELLKAY, LLC, a company incorporated in the State of New Jersey, United States of America. ELLKAY, LLC is a leader in healthcare connectivity and interoperability solutions.

ANTI-SLAVERY AND ANTI-HUMAN TRAFFICKING POLICIES

ELLKAY does not tolerate modern slavery or human trafficking in our organization or in our supply chain. As a professional services company in the healthcare industry, ELLKAY considers the risks of modern slavery minimal compared to other industries. Regardless, ELLKAY takes the measures set forth in this statement to ensure such obligations are taken seriously.
In support of ELLKAY’s mission and values, employees are required to comply with an extensive Code of Ethics Conduct that specifically requires acknowledgement of applicable laws and regulations to maintain corporate integrity and a culture of respect. Additionally, employees complete regular trainings on workplace behavior, including but not limited to, trainings regarding workplace harassment.

SUPPLY CHAIN AND DUE DILIGENCE

ELLKAY service and procurement agreements require ELLKAY business partners to comply with all applicable laws that relate to its relationship with ELLKAY, including, but not limited to, modern slavery laws, as appropriate.

EFFECTIVENESS

ELLKAY believes that its efforts as outlined in this statement have been appropriate in preventing modern slavery and human trafficking from entering its supply chains.

GOING FORWARD

ELLKAY remains committed to continued employee training and implementation of its Code of Ethics Conduct and to an unwavering intolerance of any practice related to the exploitation or manipulation of either its own ethical code or that of the Act.
ELLKAY identified the following steps which it believes will further enhance ELLKAY’s commitment to this cause:

• Integration of a modern slavery policy into the ELLKAY Code of Ethics Conduct.
• Incorporating a modern slavery policy into the Employee Handbook for annual receipt and acknowledgement.
• Improving employee training and awareness regarding modern slavery and trafficking.
• Improving and incorporating additional statements to third party due diligence specifically relating to modern slavery and trafficking.
• Monitoring changes in law and implementing any additional measures, as appropriate.

This Statement is approved and signed by Kamal Patel, Director, on behalf of ELLKAY International Limited.