Business Code of Conduct

Arian Medical Code of Business Conduct and Employment Standards Policy

At Arian Medical, we believe that business should be conducted honestly, fairly and with respect for people, their dignity and their rights. This Code is intended to make clear what this means in practical terms.

It sets out the standards of behaviour by which we manage the organisation. We expect and require that all managers and employees of Arian Medical apply the same standards in their dealings with other people and organisations.

What are we in business for?

We are in business to create long-term value by supplying products and services of quality, reliability, compliance and value, and by dealing fairly with our customers.

To build a sustainable business, we aim to develop strong and trusted relationships with our customers and suppliers. We will do this honestly, fairly and with respect for people and the natural environment.

We are committed to continual improvement in all areas of our business and business practices and set measurable objectives which are reviewed through our Quality Management System meetings.

To continue to grow and prosper, we increasingly need to build partnerships with our customers and suppliers. Such partnerships must be based on mutual trust, and we will seek to earn that trust by operating according to the principles set out in this document.

Regulatory Commitment

Arian Medical is committed to complying with all applicable UK regulatory requirements relating to the products we supply, distribute or support.

This includes products falling within the scope of:

• medical devices
• personal protective equipment (PPE)
• biocidal products
• cosmetic products
• general consumer products

Where applicable, we fulfil our responsibilities as importer, distributor or UK Responsible Person in accordance with relevant legislation and regulatory requirements.

We work in accordance with the requirements of relevant UK competent authorities, including the Medicines and Healthcare products Regulatory Agency and the Office for Product Safety and Standards, where applicable to product category and supply route.

Stakeholders

A number of people and organisations are affected by our actions and to whom we have responsibilities. These include our employees, customers, suppliers, other business partners such as distributors, service providers, contractors and the wider community.

Status of this Code

This Code has overriding status in governing the standards of our business behaviour. All contracts entered into by Arian Medical should be consistent with it. If there are any inconsistencies, we will act in accordance with the standards set out in this Code rather than lower standards set elsewhere.

In running our business, Arian Medical is required to observe the standards of conduct set out below.

Standards of Behaviour Towards Employees

Our employees are one of our greatest assets. Our continued success depends on their skills, commitment and professionalism.

We will:

• respect the human rights of all employees
• provide good, safe and healthy working conditions
• provide competitive pay and employment benefits
• offer fair terms of employment through clear contracts that fairly set out mutual responsibilities
• promote the development and best use of people’s talents
• select, train and promote employees fairly and on merit, giving equal opportunities to all
• not discriminate on grounds of race, colour, religion, nationality, ethnic origin, political opinion, sexual orientation, marital status, gender, age, disability, part-time or fixed-term status
• ensure a working environment free from harassment and bullying
• manage people with consideration and respect, including providing feedback on performance
• ensure disciplinary procedures are documented, fair and open
• keep employees informed about relevant changes, trends and developments within the company
• not ask any employee to do anything illegal, unethical or contrary to recognised professional standards
• encourage employees to report wrongdoing or breaches of this Code confidentially through appropriate reporting channels or to a Director
• respect employees’ rights to join lawful representative organisations or to choose not to join them
• respect employees’ rights to civic activity and religious practice, subject to normal contractual obligations
• not use employment arrangements to avoid legal employment protections, social security or normal employee benefits

Standards of Behaviour Towards Customers

To continue to succeed, we need to win and retain customers by building strong business relationships.

We will:

• supply products and services that offer value in terms of price, quality, performance, safety and environmental impact
• establish mutually beneficial business relationships and seek to meet both the spirit and terms of our commitments
• seek clarity in all agreements, avoiding ambiguity wherever possible
• deal promptly with any quality or performance issues affecting products or services
• not seek business advantage through bribery, inducements or improper payments
• not offer or accept bribes, inducements or improper payments to obtain commercial advantage

Standards of Behaviour Towards Suppliers

An efficient and reliable supply chain is an important part of business success and requires strong working relationships with suppliers.

We will:

• seek mutually beneficial relationships with suppliers
• comply with both the spirit and wording of contracts
• seek clarity in all agreements
• develop business with suppliers who operate in accordance with ethical and legal standards
• expect suppliers to operate in accordance with recognised employment, safety and environmental standards
• agree clear payment terms and pay on time in accordance with those terms
• insist on honesty and integrity in supplier relationships
• not tolerate attempts to obtain business through gifts, payments or improper influence
• avoid business relationships where unlawful or unethical practices are suspected

Standards of Behaviour Towards the Wider Community

We believe that businesses should act responsibly within the wider community.

We will:

• comply fully with applicable laws and regulations
• seek to minimise adverse effects on the environment and natural resources where reasonably practicable
• encourage employees to become involved in community activities
• support relevant charitable and community organisations where appropriate

Competition

We believe in fair competition and will:

• compete fairly in the markets in which we operate
• not engage in price fixing or anti-competitive arrangements
• not seek confidential competitor information by improper means
• respect intellectual property rights

Financial Matters

All transactions by Arian Medical will be fully documented and accurately reflected in company records in accordance with established accounting procedures and subject to internal and external review where appropriate.

Confidentiality

We will safeguard confidential information relating to employees, customers, suppliers and business partners. Such information will only be made available where necessary for legitimate business purposes.

Review

This Code is reviewed periodically as part of the company’s management review process.

Approved by: Director
Version: 1.0
Review Date: April 2026