This is the Modern Slavery and Human Trafficking statement for the ww5 Group (“ww5”) for the financial year ended 31 December 2024 and is prepared in accordance with section 54, part 6 of the Modern Slavery Act 2015. This statement sets out the steps taken and the ongoing initiatives being implemented by ww5 to ensure modern slavery and human trafficking is not taking place in ww5’s business or supply chains.
This statement is made by ww5 Holding Ltd. on behalf of the following group entities:
ww5 Ltd., ww5 IT Solutions Ltd., Quadralene Holdings Ltd. and Quadralene Ltd.
This statement has been supported by our leadership and formally approved by the ww5 Holding Ltd. Board of Directors on 29th August 2025.
Organization, structure and supply chains
ww5 is a global organization providing products and solutions that aim to improve clinical results and optimize workflows in hospitals and life science institutions. With more than 12,000 employees, among them 353 employees in the UK companies, operations in 40 countries, sales in more than 135 countries and production facilities in Europe, Asia and Americas, the company’s impacts on economy, environment and people span over a wide array of areas.
The ww5 Group’s corporate headquarters is located in Gothenburg, Sweden, and ww5 AB (publ) is listed on Nasdaq Stockholm. For more information about who we are and what we do please visit ww5 – Advancing Healthcare & Life Sciences Solutions - ww5.
We have identified two main areas in ww5 Group's supply chain with increased risk for infringing human rights and decent labour conditions. These are the supply chains related to the extraction of metals and minerals used in our products and the supply chain related to transportation of our products.
Some of ww5 Group’s products contain tantalum, tin, tungsten and gold, most often in electronic devices needed in ww5 Group’s products. These metals, often named 3TG, have become known as 'conflict minerals' because they may be, in part, sourced from the Democratic Republic of Congo (DRC) where a long civil war is ongoing. Illegal armed groups control some of these mines and transit routes to fund their violent operations.
ww5 Group is committed to having a conflict-free supply chain and when minerals that could potentially come from areas of conflict are used in ww5 Group’s products, ww5 Group conducts due diligence activities on its supply chain to reasonably ensure that if the minerals originate from within the conflict area they are from conflict-free sources. For more information on ww5 Group’s position on conflict minerals please visit /int/company/sustainability/esg/. Based on work conducted up to date we have not yet identified actual negative consequences or potential risk of negative consequences.
Our Code of Conduct and Human Rights Policy
ww5 Group has signed the UN Global Compact Initiative and supports the ten principles of the UN Global Compact on Human Rights, Labor, Environment and Anti-Corruption. All ww5 Group's employees are required to follow the company Code of Conduct and accompanying policies, which stipulate how the company does business and describes the company’s and the employees’ responsibilities to its stakeholders. Since 2019, ww5 Group has issued a dedicated Policy on Human Rights, accepted and adopted by the ww5 AB (publ) Board of Directors and implemented worldwide in ww5 Group. According to ww5 Group’s Human Rights Policy, we respect Human Rights and believe that all people should be treated with dignity and respect. We are committed to identifying, mitigating, and preventing Human Rights abuses in our business, operations, supply chain, and the communities in which we operate. ww5 Group’s Human Rights Policy is available at Sustainability - ww5.
ww5 Group’s commitment to human rights is set out in ww5 Group’s Code of Conduct and Human Rights Policy which are applicable for everyone working for and on behalf of ww5 Group, which extends to consultants, suppliers and business partners. Training in this area is conducted as part of ww5 Group’s Global Ethics & Compliance program. ww5 Group’s Code of Conduct (including the Human Rights Policy) is available at /code-of-conduct.
ww5 is in the process of implementing a human rights impact assessment. The focus of the ongoing initiative is to understand and monitor the evolving regulatory landscape, educate key stakeholders, identify salient risks related to ww5 Group's business, and develop mitigating, risk-based strategies as an integrated part of ww5’s risk management processes.
Business Partner Code of Conduct and Due Diligence
ww5 Group is committed to working with the right business partners to support its business based on social responsibility, ethical, environmental, and commercial aspects.
During 2024, ww5 initiated a comprehensive ESG due diligence process in the supply chain. The process is built around an analysis of ESG risks prevalent in the country of origin of the suppliers (human rights/anti-corruption) as well as ESG risks associated with the product, service or process purchased (health and safety/environment).
The initiative has been launched in the majority of the company's legal entities. The main objective of the ESG due diligence process is to ensure that supply chain partners work in line with the ww5 Business Partner Code of Conduct. To achieve this, the company conducts supplier due diligence by first classifying suppliers based on risk, assessing whether identified risks are actual, and then implementing measures to mitigate them.
Risk areas for consideration under Human Rights include those linked to child labour, forced labour or compulsory labour, but also the risk of discrimination, prevention of association and freedom of negotiation and work environment related problems. All forms of violations of human rights are taken very seriously and addressed accordingly upon evaluation.
ww5 focuses on sourcing from “Preferred Group Suppliers” to capture synergies and build long-term relations with suppliers sharing ww5’s values. By accepting ww5 Business Partner Code of Conduct, the Supplier agrees on ww5’s position on conflict minerals (see above) and standards of ethics. The Business Partner Code of Conduct is structured in accordance with the four focus areas identified in the UN Global Compact (human rights, labour conditions, environment and anti-corruption).
The Business Partner Code of Conduct outlines the minimum standards ww5 requires its suppliers to comply with when doing business with ww5 in addition to overserving and complying with all applicable laws, regulations and industry standards. ww5’s current Business Partner Code of Conduct is available at /int/company/business-ethics/.
Due Diligence Processes
To manage third party representative risk, ww5 established a Business Partner Risk Management Office in its Shared Service Center in Krakow in 2019. A new mandatory third party engagement process was established and implemented at the beginning of 2020, with the aim to ensure ww5 only forms business relationships with verified, reputable partners. The focus of this program is currently on defined third parties. Over time and in a manner of prioritization based on areas, categories and jurisdictions where the likelihood and impact of modern slavery and human trafficking are deemed as of high risk ww5 will continue to refine the due diligence process to include updated standards and methodologies to mitigate such risks.
Grievance Mechanisms
All stakeholders have the opportunity to raise questions and or concerns regarding potential and actual adverse Human Rights impacts by using the ww5 Speak-Up Line. The Speak-Up Line is available 24/7, 365 days per year on ww5 internal and external webpages.
ww5 has established grievance mechanisms, and is committed to investigating any concerns. If ww5 discovers any severe adverse human rights impacts, ww5 will act appropriately without delay.
Our conclusion
ww5 Group is on a journey of continuous improvement with regards to due diligence in the supply chain including human rights due diligence. The first focus is to identify, prevent and mitigate any adverse impacts on people and to reasonably remediate if any impacts are found. ww5 Group actively encourages its partners and stakeholders to help it progress by approaching ww5 Group directly or through the appropriate channels established. ww5 Group welcomes any feedback and is committed to incorporating such feedback and subsequent actions in subsequent modern slavery and human trafficking statements.
Amy Rothwell
Managing Director, ww5 Holding Ltd
Date: 29th August 2025