SureFlap Ltd Modern Slavery Statement

Introduction

This statement is made pursuant to the UK Modern Slavery Act of 2015 (United Kingdom). It sets out the steps that SureFlap Limited (trading as Sure Petcare) is taking to address the risk of modern slavery taking place in our business and supply chain.

Structure, Operations and Supply Chains

About SureFlap LTD.

SureFlap Ltd. (trading as Sure Petcare) , along with HomeAgain, is a Companion Animal portfolio of digital products within Merck Animal Health, which is a division of Merck & Co., Inc., Rahway, New Jersey, USA (called MSD everywhere outside of the U.S. and Canada). SureFlap Limited was acquired by MSD in 2019 as part of MSD’s acquisition of a privately held animal health intelligence company called Antelliq Corporation, which became the Merck Animal Health Intelligence (“MAHI”) business unit after the transaction was completed.

For more information, visit www.surepetcare.com.

Our Supply Chain

Our direct suppliers provide us with goods and services such as packaging and components. Our indirect suppliers include those that provide services such as logistics, travel and meetings, facility management and marketing.

Policies

Our policies serve as our standards of conduct for engaging with stakeholders. They are founded on MSD’s Code of Conduct (Our Values & Standards) and are used to navigate and guide our decisions and actions. They help us identify, address and mitigate risks associated with doing business, including the potential risk of engaging in practices associated with modern slavery.

Relevant policies and standards are summarized in the table below.

MSD’s Chief Compliance Officer and Ethics & Compliance Organization oversees our company’s global compliance program, including compliance related policies and procedures. As part of governance MSD’s Ethics & Compliance Organization oversees a tri-annual review of all MSD Corporate Policies to ensure that they remain current and relevant.

Most MSD policies, including those listed above, apply to MAHI, including SureFlap Limited.¹ There are also certain MAHI-specific policies given the nature of MAHI’s primarily technology-related business, which are inapplicable to the biopharmaceutical business.  In addition, we continue to evaluate areas where we can further integrate MAHI’s compliance program into MSD’s enterprise compliance program and MSD’s systems. The MAHI Compliance Director sits outside of, but works closely with, the MSD Ethics & Compliance Organization, with the ultimate goal of having one integrated compliance organization.

¹ MSD policies that are specific to biopharmaceutical products are not applicable to SureFlap products.

Risk of Modern Slavery Practices

Our Operations

We have robust labour, employment and recruitment practices in place intended to minimize the risk of causing, contributing to or being linked to instances of modern slavery and human trafficking within our own operations.

Our Supply Chain

We have assessed that the risk of modern slavery practices within our supply chain is predominantly associated with our use of third-party suppliers and service providers that operate in countries that are known to present a significant risk of modern slavery, such as those listed on the Walk Free Foundation’s Global Slavery Index, as well as other recognized external data sources on modern slavery and human trafficking.

We recognize that companies with supply chains that extend into high-risk countries potentially face greater risks of modern slavery. Our company can be indirectly exposed to modern slavery risks through our supply chain, as some of our third-party suppliers and service providers operate in countries that have a high prevalence of modern slavery.

Actions taken to assess and address modern slavery risks

Our Operations

We work to detect and address the risks of modern slavery within our own operations through:

Code of Conduct: Respecting and abiding by our company’s core values and standards, as stated in our company Code of Conduct. We consider these to be the foundation of our company’s success. They apply globally, wherever we are doing business.

Standards: Upholding and maintaining company standards on modern slavery and human trafficking. These are embedded in our Global Policy on Labour & Human Rights and reflected in our Public Policy Statement on Human Rights.

Speaking Up: Fostering an environment where employees feel safe to speak up and report concerns. We rely on employees to speak up about potential violations of our Code of Conduct, policies, procedures, the law or other misconduct, including any that are suggestive of modern slavery.

Tone at The Top: Communications from senior leaders emphasizing the importance of ethics and integrity and the importance of speaking up and reporting issues/concerns before they become a bigger problem.

Communication Channels: Maintaining multiple communication channels to make it easy for employees and others to ask questions or report concerns. Employees can report concerns to their Managers, Human Resources, Compliance, or Legal.

Speak Up Tool: Providing a speak up tool. The Speak Up tool at msdethics.com is operated by an independent third-party, available 24 hours a day, 7 days a week. It allows employees to raise concerns or ask questions confidentially in their preferred language via phone or the internet.

Investigations. All allegations of misconduct are investigated in accordance with our company’s Compliance Issues Visibility Response (“CIVR”) process, which promotes confidentiality, dignity and respect, objectivity, promptness and non-retaliation.

Corrective Action. We take violations seriously. Corrective and disciplinary actions are taken against individual employees who are determined to have engaged in misconduct based on the findings of an investigation, which is independently overseen by our Office of Ethics, based in the U.S.

Training: New employees, as well as existing employees receive annual training on our company Code of Conduct (Our Values & Standards) through a series of on-line compliance courses. Training completions are closely monitored and reported to senior management.

Accountability: Maintaining accountability. All employees are responsible for 1) adhering to our company’s Code of Conduct 2) complying with all relevant polices and 3) raising concerns. Substantiated violations may result in disciplinary action up to and including termination.

Our Supply Chain

We work to detect and address the risks of modern slavery in our supply chain through:

Supplier Selection: Striving to select suppliers that are socially responsible and who share our company’s commitments to ethics and legally compliant business practices. Our goal is to obtain services, goods, components, finished goods or other products in a way that is lawful, fair and aligns with the principles outlined in our Business Partner Code of Conduct (BPCC).

Expectations: Setting and communicating our expectations of suppliers, including those related to child labour, forced labour and human trafficking. We use our Business Partner Code of Conduct (BPCC) to communicate our expectations. It has been translated for all countries in which MSD operates.

Contracts: Seeking written commitment from suppliers to respect the principles set forth in our BPCC through our contracts/agreements. Our standard contract templates also contain clauses on compliance with laws, ethical business practice, right to audit/inspect, as well as contract termination.

Training: Training certain Procurement professionals with responsibility for supplier selection, oversight and monitoring, including the assignment of on-line courses on 1) BPCC; 2) Mitigating Modern Slavery Risks in Supply Chains; and 3) Third-Party Risk Management.

Assessing Effectiveness

We closely monitor training completions, particularly with respect to the Code of Conduct (Our Values & Standards), and report completion rates to senior management. As discussed below, we are also making ongoing efforts to strengthen and improve both our compliance processes and our assessment of our efforts to address the risk of modern slavery in our business and supply chain.

Next Steps

We will continue working on our efforts to identify, assess, and address modern slavery risks within our operations and supply chains and to integrate the MAHI procurement, finance, and compliance systems into MSD’s systems, including with respect to modern slavery risks. In the interim, we will work to enhance our process for conducting appropriate risk-based supplier due diligence, including by implementing the human rights self-assessment questionnaire currently used by MSD. This questionnaire will be sent to select direct materials suppliers and contract manufacturing partners, and will be used to gather information on freely chosen employment, child labor, employment practices, employee disclosures, fair treatment, wages, benefits and working hours.

We will also work to incorporate MAHI-specific suppliers into MSD’s Labour & Human Rights (LHR) audits, which are conducted using a risk-based approach at select supplier facilities to verify their conformance with our company’s expectations (as stated in our BPCC) and by working with them to address any identified non-conformities.

In addition, we will work towards providing relevant training to all professionals with responsibility for supplier selection, oversight and monitoring, including the assignment of on-line courses on 1) BPCC; 2) Mitigating Modern Slavery Risks in Supply Chains; and 3) Third Party Risk Management.

Approvals

Signed on behalf of SureFlap Ltd by Andrew Bank, Commercial Director

2^nd August 2022