MODERN SLAVERY STATEMENT
Modern Slavery Statement for Financial Year 2025
INTRODUCTION
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015.
We remain committed to acting in a professional and ethical manner in all our business activities and are dedicated to upholding the highest standards of integrity and responsibility as we develop our operations.
COMMITMENT TO ETHICAL PRACTICES
At ITF Pharma Ltd (Company number 15018988) (“ITF”), we ensure all our activities comply with relevant employment and health and safety legislation applicable within the United Kingdom. We are developing our operations with a strong commitment to creating an inclusive workplace where every employee feels valued and respected.
CODE OF BUSINESS CONDUCT AND ETHICS
Our employee manual incorporates our Code of Business Conduct and Ethics, requiring all staff to conduct their duties with the utmost ethical integrity, transparency, and responsibility. This includes maintaining responsible relationships with suppliers and partners and ensuring that our business dealings are transparent and fair.
WHISTLEBLOWING MECHANISM
We provide our employees with access to a confidential mechanism to report any unethical behaviour or violations of our business principles. This includes an anonymous whistleblower channel, allowing concerns to be raised with assurance of confidentiality and without fear of retaliation. All reports are taken seriously and are investigated thoroughly.
THE ORGANISATION
ITF is a wholly owned subsidiary of Italfarmaco, S.A., a company incorporated in Spain and with registered address in Madrid, registered with the Madrid Commercial Registry under volume 8601, Folio 196 and sheet M82156 is in turn, a subsidiary of ITALFARMACO S.p.A., a company incorporated in Italy and headquartered in Milan, registered with the Companies’ Register of Milan under R.E.A. no. 273567. The ITALFARMACO Group operates six manufacturing sites (two in Italy, two in Spain, one in Brazil and one in Chile) and conducts business in over 90 countries as at December 2025.
ITF was incorporated in the United Kingdom in July 2023. As of December 2025, ITF continued to establish its UK operations and had not commenced trade sales. Operational activity during the year remained primarily focused on preparation for future commercial activity, including the development of internal processes, governance arrangements, supplier relationships and controlled supply chain arrangements.
ANTI-BRIBERY AND CORRUPTION (ABAC) POLICY
ITF’s Anti-Bribery and Corruption Policy builds on the core principles of the Code of Ethics, is consistent with international standards and laws and provides the minimum requirements for ITF. ITF prohibits all forms of bribery and corruption, whether involving a government official or private person or entity, whether direct or through a third party.
THIRD PARTY DUE DILIGENCE
At ITF we understand there is a potential exposure to Modern Slavery when purchasing goods and services from third parties. Any third party engaged by ITF must conduct business ethically and is expected to comply with all our standards, including those laws and regulations relevant to where we operate, or the third party operates on our behalf.
During 2025, ITF’s third-party activity remained limited and proportionate to its stage of operational development. Supplier and service provider engagement continued to be focused on specialised, regulated and professional services necessary to establish the UK business and prepare for future commercial operations.
MODERN SLAVERY AND HUMAN TRAFFICKING
ITF recognises the importance of preventing any form of modern slavery or human trafficking in our operations and supply chain. Currently, our risk of encountering these issues is considered very low due to our limited operational scope and the absence of a complex supply chain. However, we remain vigilant and continue to apply due diligence processes to ensure compliance with all national and international legislation related to modern slavery and human trafficking.
ONGOING COMMITMENT
As ITF continues to establish itself and expand its operations, we commit to regularly reviewing and enhancing our policies and procedures to ensure they remain effective and relevant. We are dedicated to maintaining ethical practices across all aspects of our business and supply chain.
APPROVAL
This statement has been approved by the Board of Directors of ITF Pharma Ltd and signed by a director. It will be reviewed and updated annually to reflect any changes in our operations or compliance requirements.
Updated June 2026