MODERN
SLAVERY
AND
HUMAN
TRAFFICKING
STATEMENT
Dear business partners,
The success of our company depends on the trust of our stakeholders. We must maintain this trust and prove that we live up to it. For this reason, Balmung Medical Handel GmbH has established a code of conduct that translates the company's fundamental ethical values into behavioral guidelines. This code applies to all our employees, managers, board members and partners and must be adhered to by all.
On this page you will find our Code of Conduct which refers to the important topic of "Modern Slavery". Here you can find out all about our efforts to combat modern slavery in all its forms. We are committed to upholding ethical standards and protecting human rights throughout our supply chains. Dive in to find out more about our actions and commitment.
1. INTRODUCTION
Balmung Medical Handel GmbH is fully committed to upholding human rights and ensuring that modern slavery, human trafficking, forced labour, and exploitation of any kind have no place in our business or supply chains. We strive to conduct all operations with transparency, fairness, and accountability, in accordance with the UK Modern Slavery Act 2015.
2. CORPORATE STRUCTURE AND SUPPLY CHAIN
Balmung Medical Handel GmbH is an Austria-based medical trading and distribution company supplying high-quality medical devices and consumables to public and private healthcare institutions across Europe and globally.
Our core manufacturing partners are located in China and India, with additional logistics and warehousing services provided by partners in Europe. We maintain close and ongoing relationships with our Chinese and Indian manufacturing partners to ensure that product quality, ethical standards, and legal compliance are consistently met.
3. RISK AREAS AND DUE DILIGENCE
We recognize that the risk of modern slavery and human trafficking is heightened in certain regions - particularly parts of Asia - due to more complex labor laws and common subcontracting practices.
We therefore take targeted measures to assess and manage these risks within our supply chain, particularly at the manufacturing level. Our risk management approach includes:
- Conducting background checks and due diligence on suppliers during onboarding
- Requiring signed declarations and contractual commitments from suppliers confirming compliance with anti-slavery and labour rights standards.
- Prioritising suppliers who maintain internationally recognised certifications such as ISO 13485 and who are subject to regular third-party audits.
- Direct site visits (where possible) or documented factory audits to monitor working conditions and labour practices.
4. ACTIONS TAKEN TO PREVENT MODERN SLAVERY
To mitigate the risk of modern slavery, Balmung Medical Handel GmbH has implemented the following safeguards:
- We have integrated ethical sourcing clauses in supplier contracts, with the right to terminate agreements in case of labour rights violations.
- Employees involved in procurement and supplier management are trained to recognise potential signs of forced labour or trafficking.
- We maintain a regular review process for our supply chain, particularly focused on high-risk regions and sectors.
- We engage in ongoing communication with suppliers to promote transparency and good labour practices.
5. MEASUREMENT OF EFFECTIVENESS
We measure our effectiveness in ensuring that slavery and trafficking are not taking place in our business or supply chains using the following key performance indicators (KPIs):
- 100% of new suppliers must complete due diligence and sign compliance declarations before engagement
- Annual review of high-risk suppliers to assess compliance and identify red flags.
- Zero tolerance: Any report or credible suspicion of forced labour triggers immediate investigation and appropriate escalation.
- Training completion rate for relevant staff on ethical procurement and slavery risk awareness.
We also track internal and supplier-reported incidents and continuously refine our controls based on these learnings.
6. FUTURE OBLIGATIONS
In our ongoing commitment to ethical business conduct, we plan to:
- Increase supply chain transparency by requesting more detailed reporting from our manufacturing partners.
- Introduce a supplier self-assessment questionnaire aligned with UN Guiding Principles on Business and Human Rights.
- Expand training to include updates on modern slavery regulations and regional risk factors.
- Explore options for commissioning independent audits of manufacturing sites in China.
7. APPROVAL AND REVIEW
This statement has been approved by the management of Balmung Medical Handel GmbH and is reviewed annually to ensure alignment with evolving laws and best practices in human rights and supply chain governance.
Signed on behalf of the Supplier:
Engelbert Leobacher, CEO, Balmung Medical Handel GmbH
February 2026