Modern Slavery & Human Trafficking Policy

VRiMS
Version: 1.0
Last reviewed: September 2026
Review frequency: Annually

1. Our Commitment

VRiMS is committed to conducting its business ethically, responsibly and with integrity. We have a zero-tolerance approach to modern slavery, human trafficking, forced or compulsory labour, servitude, child labour and other forms of exploitation.

We are committed to taking reasonable and proportionate steps to prevent modern slavery within our organisation and our supply chain, in accordance with the principles of the Modern Slavery Act 2015.

2. About VRiMS

VRiMS provides immersive technology, extended reality (XR), artificial intelligence and digital solutions for medical and surgical education and training.

As a small UK organisation, our direct workforce and supply chain are relatively limited. Nevertheless, we recognise that modern slavery can occur within organisations and supply chains of any size and that all businesses have a role in identifying and reducing this risk.

3. Scope

This policy applies to everyone working for or on behalf of VRiMS, including directors, employees, contractors, consultants and other individuals or organisations providing services to us.

We also expect our suppliers, partners and subcontractors to operate in accordance with applicable employment, labour and human rights legislation and to share our commitment to preventing modern slavery and exploitation.

4. Our Principles

VRiMS will:

• Not knowingly engage with any organisation involved in modern slavery, forced labour, human trafficking or exploitation.

• Treat individuals working for or with VRiMS fairly and with dignity and respect.

• Comply with applicable UK employment and labour legislation.

• Take a proportionate, risk-based approach when selecting and reviewing suppliers and business partners.

• Consider ethical employment and modern slavery risks as part of our supplier due diligence where appropriate.

• Investigate credible concerns relating to modern slavery or exploitation.

• Take appropriate action where a supplier or partner fails to meet the standards we expect.

5. Our Supply Chain

Our activities may require us to purchase technology, software, professional services, equipment and other products and services from third-party suppliers.

We recognise that risks may exist further down global supply chains, particularly in relation to the manufacture of electronic and technology products.

We therefore seek to work with reputable suppliers and organisations that operate responsibly and comply with applicable laws and regulations.

Where the nature, location or activities of a supplier indicate an increased risk of modern slavery, VRiMS may undertake additional due diligence or seek appropriate assurances regarding the supplier's employment and supply-chain practices.

6. Recruitment and Working Practices

VRiMS is committed to fair and lawful working practices.

We do not support the use of forced, bonded or involuntary labour. Individuals working for VRiMS must be free to leave their employment or engagement in accordance with their contractual arrangements and applicable law.

We will not knowingly employ or engage individuals who are being subjected to coercion, exploitation or unlawful employment practices.

7. Reporting Concerns

Anyone working with VRiMS, including suppliers and business partners, is encouraged to raise concerns if they suspect that modern slavery, human trafficking or exploitation may be occurring within our organisation or supply chain.

Concerns can be raised confidentially by contacting:

Email: info@vrims.net

All credible concerns will be considered seriously and handled appropriately. No individual should suffer detrimental treatment for raising a genuine concern in good faith.

8. Responding to Modern Slavery Risks

Where VRiMS identifies or receives credible information about potential modern slavery within its operations or supply chain, we will take appropriate and proportionate action.

This may include seeking further information from the supplier or partner, requesting corrective action, suspending or terminating a commercial relationship, or referring concerns to the appropriate authorities where necessary.

Our priority will be to respond responsibly and avoid actions that could inadvertently increase the risk of harm to affected individuals.

9. Responsibility

Responsibility for implementing and reviewing this policy rests with the senior management of VRiMS.

Given the size of our organisation, modern slavery risk forms part of our wider approach to responsible business, governance, procurement and supplier management rather than being managed by a separate dedicated team.

10. Training and Awareness

VRiMS will maintain appropriate awareness of modern slavery risks and responsibilities within the organisation.

As the organisation grows, we will review whether additional formal training, supplier assessment processes or other controls are appropriate.

11. Monitoring and Review

We are committed to continually improving our approach to identifying and managing modern slavery risks.

This policy will be reviewed at least annually and may be updated sooner following significant changes to our organisation, supply chain, relevant legislation or identified risks.

12. Approval

This policy has been approved by the senior management of VRiMS and represents our commitment to preventing modern slavery and human trafficking within our organisation and supply chain.

VRiMS
September 2026