Modern Slavery Act

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for another person's gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

At Orchid Orthopedic Solutions we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking.

Organization Structure and Supply Chains

•   Orchid Orthopedic Solutions offers contract design and manufacturing services for Orthopedic procedures
•   The Company is headquartered in Michigan, USA
•   The Company has facilities located in the USA, UK, Switzerland and China
•   The Company has a Supply Chain which is Global in nature

Policies in relation to Modern Slavery

Orchid Orthopedic Solutions operates the following arrangements for communicating requirements for labor standards, and the reporting of modern slavery throughout our Supply Chain:

Procedures which define how Orchid approach the identification of risks associated with Labor practices through the Supply Chain, and how potential areas of risk are resolved
Supplier Code of Conduct– A Code of Conduct making clear Orchid’s requirements relating to Labor Standards, and how to report concerns to Orchid
Whistleblowing Hotline – An externally hosted service which is available for the reporting any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers.

Due Diligence

In the past year, we have conducted a risk assessment of our supply chain1 by taking into account:

The risk profile of individual countries based on the Global Slavery Index
The business services rendered by the Suppliers
The level of interaction between the Supplier and Orchid Orthopedic Solutions

Risk Assessment and Management

100% of the Suppliers which were assessed are located in a Country which falls into a country with a weighted average for Slavery Risks of 0-20 (refer to GlobalSlavery.org, 2018 report, Table 14, page 156)
Orchid Orthopedic Solutions do not procure any Product or Service which falls into a high risk imported activity (refer to GlobalSlavery.org, Top 5 Risks – US, appendix 3)
The highest risk ‘’product or services’’ identified in the assessment are Metal Conversion and Finishing
Orchid have assessed that 0% of Suppliers are high risk. 5% of Suppliers are medium risk. 95% of Suppliers are low risk.

The Management of Suppliers will be performed in line with their assigned risk, and in accordance with the procedures which define how potential areas of risk are resolved.

Key Performance Indicators to Measure the Effectiveness of Steps being taken

Orchid Orthopedic Solutions has defined a set of key performance indicators and controls to combat modern slavery throughout our supply chain. These are:

The percentage of Human Resources, Supply Chain and Purchasing Personnel who have completed training in procedures relating to labor practice governance through the Supply Chain
The percentage of High & Medium Risk Suppliers who have signed up to Orchid’s Supplier Code of Conduct
The number of violations relating to Modern Slavery which have been reported to Orchid

Training on Modern Slavery and Trafficking

Orchid Orthopedic Solutions intends to raise awareness of modern slavery and trafficking issues by training Supply Chain and Purchasing personnel in:

Procedures relating to labor practice governance through the Supply Chain
Our commitment in the fight against modern slavery and trafficking
Red flags for potential cases of modern slavery and trafficking
How employees should report suspicions of modern slavery and trafficking

These activities are planned to complete by the end of 2021.

This statement is made pursuant to section 54(1) Part 6 of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31 December 2020 and reflects the position at the date of issue of this statement.

For and behalf of the Orchid Orthopedic Solutions Board of Directors

Nate Folkert
Chief Executive Officer
Orchid Orthopedic Solutions
Date: October 6, 2021

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1 The Risk Assessment was performed on immediate Suppliers falling into the top 95% of Orchid Orthopedics Global Spend (n= 413 suppliers). The survey did not extend to a Suppliers downstream supply chain

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