This statement is made by Medical Ocean LTD, a company registered in England and Wales (Company No. 14943900) with its registered office at 86-90 Paul Street, London EC2A 4NE, United Kingdom (“Medical Ocean”, “we”, “us”). It is published pursuant to section 54 of the Modern Slavery Act 2015 and describes the steps we have taken during the financial year to ensure that slavery, servitude, forced or compulsory labour, and human trafficking (together, “modern slavery”) are not taking place in our business or our supply chains.

1. Our organisation and business

Medical Ocean develops and supplies enterprise healthcare software — electronic health records, pharmacy management, anesthesia, laboratory information, HR & payroll, and incident reporting applications — to healthcare organisations in the United Kingdom, the Kingdom of Bahrain, the Kingdom of Saudi Arabia, the United Arab Emirates, the Hashemite Kingdom of Jordan, and globally.

We are a software business: our principal input is the skill of our people, and our team is based in, and engaged in accordance with the employment laws of, the United Kingdom. While our customers are located in several countries, our supply chain consists predominantly of established technology vendors. Having assessed the nature of our business, our workforce, and where we source goods and services, the Board considers the risk of modern slavery occurring in our business and supply chains to be low. A low risk is not a reason for complacency, and the measures below reflect our commitment to keeping it that way.

2. Our policy

We operate a zero-tolerance policy towards modern slavery in any form. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls so that modern slavery is not taking place anywhere in our own business or in any of our supply chains. We will not knowingly enter into business with — and will discontinue any relationship with — any organisation involved in modern slavery.

This commitment is supported by related policies that apply across the company, including our code of conduct, equal opportunities policy, whistleblowing policy, and anti-bribery and corruption policy.

3. Our people and recruitment

We carry out due diligence on everyone who works for us, whether employed or engaged as a contractor:

4. Our supply chain

Our suppliers are predominantly providers of cloud infrastructure, software tools, telecommunications, professional services, and office services. They are largely based in the United Kingdom, the European Union, and the United States, and none of our direct sourcing takes place in sectors or countries identified as high-risk for modern slavery.

Our supplier due diligence includes:

To date, we have not identified any instance of modern slavery in our business or supply chains.

5. Raising concerns

Our whistleblowing policy encourages everyone who works for us — and anyone who works with us — to report any concern about wrongdoing, including any suspicion of modern slavery, in confidence and without fear of reprisal. Every report is taken seriously, investigated, and the person reporting is protected. Concerns may be raised internally with senior management or by email to admin@medicalocean.co.

6. Training and awareness

All staff complete compliance training covering our code of conduct, whistleblowing, and anti-bribery policies. Staff involved in procurement and supplier management receive guidance on recognising the signs of modern slavery and on the due diligence steps described in this statement, so concerns can be identified and escalated early.

7. Measuring effectiveness

We assess the effectiveness of these steps through the proportion of staff whose right-to-work and background checks are complete and current, the coverage of our supplier register and onboarding checks, the number of modern slavery concerns raised and how they were resolved, and an annual review of this statement and the policies behind it.

8. Approval

This statement was approved by the Director of Medical Ocean LTD and is reviewed and updated annually.

Yazid Jibrel
Director, Medical Ocean LTD
12 June 2026