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Environmental, Social, and Governance (ESG) Policy

1. Purpose

This policy formally establishes Allmed Group’s commitment to Environmental, Social, and Governance (ESG) principles and aligns our operations with the International Finance Corporation (IFC) Performance Standards on Environmental and Social Sustainability.

Through this policy, Allmed Group commits to:

  • Proactively managing ESG risks and minimizing potential impacts across all business activities.
  • Identifying and leveraging opportunities to enhance sustainability performance and create shared value.
  • Protecting people, communities, and the environment throughout our operations and supply chain.
  • Strengthening governance, compliance, and ethical business practices at every level of the organization.
  • Ensuring transparency and accountability by regularly communicating ESG performance to stakeholders, regulators, and partners.

This policy serves as the foundation for integrating ESG considerations into strategic decision-making, operational processes, and corporate culture, ensuring that Allmed continues to operate responsibly and sustainably.

2. Scope

This policy applies to:

  • All Allmed Group legal entities, subsidiaries and joint ventures where Allmed has operational control.
  • All employees, officers, directors, contractors, consultants and temporary workers carrying out activities on behalf of Allmed.
  • All operations including R&D, manufacturing, packaging and sterilization, distribution, marketing, and corporate functions.
  • Suppliers, business partners, and third parties whose contractual or operational relationships may present environmental, social, or governance (ESG) risks, where the Company endeavors and encourages ESG alignment, while taking into account availability, risk prioritization, and the need to ensure business continuity.

Exceptions require documented approval by the Head of ESG.

3. Definitions

  • ESG: Environmental, Social and Governance.
  • IFC PS: International Finance Corporation Performance Standards on Environmental and Social Sustainability.
  • Materiality: The threshold at which an ESG topic could influence the assessments or decisions of stakeholders.
  • ESMP: Environmental and Social Management Plan.

4. Policy Statement

Allmed Group commits to conducting business in a manner that protects the environment, respects and promotes human rights and labour standards, contributes positively to communities, and is governed by strong ethical practices. This commitment is integrated into Allmed’s corporate strategy, operations, procurement, and product lifecycle activities.

4.1 Environmental Commitments

Allmed will:

  • Comply with all applicable environmental laws, permits and regulatory requirements.
  • Prevent pollution and minimize environmental impacts from operations, including emissions to air, discharge to water, and waste generation.
  • Manage energy and resource efficiency with targets to reduce energy intensity, water consumption and waste generation per unit of production.
  • Promote lifecycle thinking in product design (eco-design), packaging minimisation, and responsible product stewardship.
  • The Company encourages and prioritizes sourcing materials and suppliers with a low environmental footprint and proven suitability for medical applications, to the extent practicable, taking into account availability, risk-based prioritization, and business continuity needs.
  • Set and publish, where feasible, science-based or internally justified targets for GHG reductions.
  • Prepare and maintain site-level Environmental and Social Management Plans (ESMPs) for significant operations.
  • To demonstrate the compliance with ISO 45001

4.2 Social Commitments

Allmed will:

  • Respect, protect and promote human rights consistent with the ISO 26000, IFC Principles on Business and Human Rights and IFC Performance Standards.
  • Prohibit forced labor, child labor and human trafficking in all operations and supply chains.
  • Ensure nondiscrimination, equal opportunity and respect for diversity and inclusion across the workforce.
  • Provide safe and healthy working conditions, aligned with ISO 45001 principles and local regulations.
  • Provide living-wage aligned compensation where applicable and comply with applicable wage and hour laws.
  • Encourage worker participation and representation, and maintain grievance mechanisms that are accessible, predictable and transparent.
  • Engage positively with host communities, evaluate potential community impacts, and implement mitigation or enhancement measures as needed.

4.3 Governance Commitments

Allmed will:

  • Maintain robust governance structures and board-level oversight for ESG risks and performance.
  • Enforce a zero-tolerance policy for bribery, corruption and unethical business conduct, consistent with ISO 37001 and applicable anti-bribery laws.
  • Maintain clear policies on conflicts of interest, gifts and hospitality, and political contributions.
  • Uphold data protection and cybersecurity measures to protect patient, employee and corporate information.
  • Implement transparent reporting practices and ensure accuracy in sustainability disclosures.
  • Provide whistleblower channels with protection from retaliation.

5. Alignment with IFC Performance Standards

Allmed’s ESG approach is explicitly aligned to the IFC Performance Standards. The following summary maps key Allmed commitments to IFC PS requirements:

PS1 – Assessment & Management of E&S Risks and Impacts

  • Implement systematic E&S risk assessment, develop ESMPs, integrate E&S into corporate management systems (ISO 13485 linkage), and ensure stakeholder engagement.

PS2 – Labor & Working Conditions

  • Commit to fair labor practices, health & safety programs (including LAF/sterilization safety where applicable), non-discrimination, and grievance mechanisms.

PS3 – Resource Efficiency & Pollution Prevention

  • Implement pollution prevention controls, energy and water efficiency measures, chemicals management, and waste hierarchy practices.

PS4 – Community Health, Safety & Security

  • Assess and manage community impacts from operations (facility emissions, logistics routes), emergency preparedness and response, and community engagement plans.

PS5 – Land Acquisition & Involuntary Resettlement

  • Not applicable under normal operations. Any project triggering land acquisition or resettlement requires a dedicated plan and IFC-aligned mitigation.

PS6 – Biodiversity Conservation & Sustainable Management of Living Natural Resources

  • Avoid sensitive biodiversity impacts; where unavoidable, implement mitigation and offset measures aligned with PS6.

PS7 – Indigenous Peoples

  • Where operations affect indigenous peoples, ensure culturally appropriate consultation and safeguards.

PS8 – Cultural Heritage

  • Identify and protect cultural heritage resources and avoid adverse impacts.

6. Management System & Integration

Allmed will integrate ESG into existing management systems and quality frameworks (ISO 13485, ISO 9001, MDSAP, MDR, WHO rules and other applicable regulatory and legal requirements). Key integration points include:

  • Documented policies and procedures.
  • Risk management and change control processes that capture E&S impacts (e.g., packaging materials, sterilization validation changes, supplier changes).
  • Management review and board reporting on ESG performance.
  • Internal audit and corrective action processes covering ESG topics.
  • Human resources policies and training approach.

7. Roles and Responsibilities

  • Board of Directors: Provide oversight, approve ESG strategy and targets, receive periodic ESG performance reporting.
  • CEO / Executive Leadership: Ensure resourcing and accountability; champion ESG integration across functions.
  • ESG Committee: Cross-functional committee (EHS, Procurement, Legal, HR, Operations and Quality) to drive policy implementation and oversee KPI progress.
  • Head of ESG / Sustainability: Policy owner; coordinates ESG strategy, reporting and stakeholder engagement.
  • Head of EHS / QMS / Quality: Ensure operational controls for environmental and occupational health and safety.
  • Head of Procurement: Implement supplier due diligence, contractual clauses and supplier monitoring.
  • HR Manager: Lead labor policies, training, diversity and inclusion programs.
  • Local Site Managers: Implement site-level ESMPs, maintain records, report incidents and KPIs.
  • All Employees & Contractors: Comply with policy, participate in training, report incidents and potential ESG concerns through established channels.

8. Implementation & Operational Controls

Implementation of the policy is operationalized through procedures, standards and site-level controls. Core elements are summarized below.

8.1 Environmental Controls

  • Permits & Compliance: Maintain and monitor environmental permits and regulatory obligations.
  • Emission & Discharge Controls: Install and monitor engineering controls for air emissions, wastewater treatment and controlled discharges where applicable.
  • Energy Management: Implement energy audits, efficiency projects, and consider renewable energy procurement.
  • Water Management: Monitor water usage, apply water-conservation measures and treat effluents to meet discharge standards.
  • Waste Management: Adopt waste hierarchy (avoid, reduce, reuse, recycle, recover, dispose); manage hazardous waste in line with regulations and best practice.
  • Chemical Management: Maintain an approved chemicals list, Safety Data Sheets (SDS), storage, transport and substitution where feasible.
  • Product Stewardship & Eco-Design: Incorporate environmental considerations in product and packaging design, including sterilization compatibility and end-of-life management.

8.2 Social Controls

  • Labor Practices: Enforce recruitment and employment procedures to prevent child or forced labour, ensure contractual clarity and transparent payroll practices.
  • Occupational Health & Safety: Apply risk assessments, safe work procedures, PPE, incident investigation and root cause analysis.
  • Training & Competency: Maintain training records and competency assessments for critical roles (e.g., sterilization operators, packaging technicians).
  • Worker Engagement: Establish worker committees or representatives and ensure channels for feedback.
  • Community Engagement: Conduct community mapping, engage in stakeholder consultations, and implement community investment programs aligned with license-to-operate requirements.

Conclusion

Allmed Group is fully committed to embedding Environmental, Social, and Governance (ESG) principles across all operations and decision-making processes. We recognize that long-term success is built on responsible business practices, environmental stewardship, respect for human rights, and strong corporate governance.

Through the implementation of this ESG Policy, we will:

  • Continuously monitor and improve our environmental performance, reducing carbon footprint and resource consumption.
  • Foster a safe, diverse, and inclusive workplace while supporting the health, well-being, and development of our employees.
  • Engage with stakeholders and communities transparently, investing in initiatives that create shared value.
  • Uphold the highest standards of governance, ethics, and compliance with all applicable laws and international best practices.

This policy is subject to periodic review to ensure its ongoing relevance and effectiveness, reflecting emerging standards, stakeholder expectations, and business needs.

By aligning our strategy and actions with global ESG frameworks, we aim to build a resilient, responsible, and sustainable future for all stakeholders.

Document Control

All copyright© Reserved to Allmed Group

Ref. no. Rev. no. Page 1 of 4 Issue Date Effective Date
QR.1529 01 T005 18.12.2025 18.12.2025

VAT No. GB 177361487

Company No. 07966208

© 2017 Allmed Medical Care Holdings Limited.
All rights reserved.

Building 7, Chiswick Park
566 Chiswick High Road London W4 5YG

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