Modern Slavery Statement
For year ending 2023

Information Classification: GeneralContents
1.

We are Norstella

2.

What is Modern Slavery?

3. Overall business risk

4. Our policies
5. Our supply chain
6. Mitigating the risk ofmodern slavery
7.

Governance2
Information Classification: GeneralWe are Norstella
Norstella is comprised of five separate business units: Citeline, Evaluate,MMIT, Panalgo and The Dedham Group. Pharma Intelligence U.K Limited(trading name “Citeline”) and Evaluate Ltd (“Evaluate”) which are bothregistered in the UK.
Citeline and Evaluate each have an annual global turnover which exceeds
the reporting threshold and therefore are required to publish a statement
on modern slavery. Norstella has decided to report one statement which
will cover all five businesses as an indication of our commitment totackling modern slavery globally.
At Norstella, our mission is simple: to help patients gain access to lifesaving therapies. We turn that into a reality by helping our clientsnavigate the complexities at each step of the drug development life cycle,
from pipeline to patient.
We have a zero tolerance approach to Modern Slavery and are
implementing effective controls to make certain that we are compliant
with our obligations under the Modern Slavery Act 2015.

Information Classification: GeneralMichael Gallup - CEO3

Stronger, together

What is Modern Slavery?
Modern slavery is a crime and a violation of
fundamental human rights. It takes variousforms, such as slavery, servitude, forced andcompulsory labour, child labour and humantrafficking.
All of which contribute to thedeprivation of a person’s liberty by another inorder to exploit them for personal or commercial
gain.
Norstella has a zero-tolerance approach tomodern slavery. We are committed to acting
ethically and with integrity in all our businessdealings. As a new group of companies, we arealso implementing and enforcing effective
systems and controls to ensure modern slavery
is not part of our business or supply chain.

We seek to ensure transparency in our own
business and in our approach to tackling modern
slavery throughout our supply chain, consistent
with our obligations under the UK’s Modern Slavery
Act 2015 as well as aligned United States
Government’s policy and contract obligations
prohibiting trafficking in persons and other relevant
regulations. We expect the same high standards
from all of our contractors, vendors and otherbusiness partners which is documented in our 3rdParty
CodeofConduct,availableon
www.norstella.com.

4Information Classification: General

Overall Business Risk
The risk of modern slavery is consideredthrough reviewing:••

the geographical locations of Norstella’s
operations and the low prevalence offorced labour in these areas;
the policies adopted by Norstella and theassurance processes in place;•Norstella’s recruitment processes; and•the absence of reported concerns orincidents regarding forced labour to dateWe therefore consider the risk of modern
slavery and human trafficking occurring within
our operations to be low and the mitigating
activities described below to be proportionateand effective.

Information Classification: General

Norstella committed to preventing modern slavery
throughout our organisation and supply chain. We
have undertaken the following steps to identify andmitigate the risk of modern slavery:•Utilise where possible consistent and standard
contractual terms to prevent modern slavery in
our supply chain;•

Conduct due diligence in our recruitment
process and our vendor onboarding process;•Deploy our new global Code of Conduct andWhistleblowing Policy for all employees•Roll out a new Supplier Code of conduct which
includes a prohibition on modern slavery•Communicate our Speak Up Line for all
employees, to provide a safe and confidential
means to report breaches; and•The development
programme.

ofourinternaltraining
5

Our Policies

Norstella is committed to combatting modern slavery in all forms across oursupply chain. We have created the below global internal policies andprogrammes during 2023, to help fulfil our commitment:
Code of Conduct
Our Code of Conduct clarifies what we expect from employees and offers guidance on how to embody our values on adaily basis. We require all Norstella employees to act with the highest levels of integrity and to follow our company
principles.
The Code also contains our approach to Modern Slavery which applies to all employees. It emphasises our obligations andeach employees’ individual responsibilities.
The Code also sets out our commitment to uphold our employees’ human rights and support the Ten Principles outlined in
the United Nations Global Compact, relating to human rights, labour, the environment, and corruption.
6Information Classification: GeneralOur Policies
Speak Up / Whistleblowing Policy
Our Whistleblowing Policy encourages employees and those doing business on behalf of Norstella toreport any instances of wrongdoing. Our policy ensures those reporting will be protected from retaliation
and reports will be investigated confidentially.
ESG Policy
Our ESG policy documents our values in relation to the management of social, ethical, and environmental
matters as it sets out our commitment to protect the health, safety and welfare of employees , visitors andthird parties, as well as support the principle of equal opportunities in employment, diversity and inclusion,offering fair levels of remuneration alongside our annual Gender Pay Gap Report.

7
Information Classification: GeneralOur Supply Chain
As a new company, Norstella is setting up acentral functions team which supports theonboarding and assessing of the supply chain.
This includes support from IT, Legal, Compliance,
InfoSec, and Privacy. Tools have been
implemented to review contracts, due diligence,and risk in the supply chain.
As mentioned previously, we expect our suppliers,
their employees, and their supply chains tooperate in a way that supports our commitment
to strong ethical standards and can commit tothis by agreeing to compliance with the 3rd party
Code of Conduct.

8Information Classification: GeneralMitigating the risk of modern slavery
Combatting Trafficking in Persons. As a supplier to the UnitedStates Government and US Government prime contractors, we fully
support the US Government’s zero tolerance policy prohibiting
trafficking in persons and, as required by US Regulations, we areadopting a compliance plan to establish mandatory procedures tocombat human trafficking and modern slavery in our organisation.

Whilst US regulatory requirements mandate that the Compliance
Plan be implemented at certain sites which perform work on behalfof the US Government, we recognise that the Plan represents
current best practice in this area and are extending it across ourentire company.
Standard Purchasing Conditions. Where possible, vendors areencouraged to agree to our standard purchasing conditions andcomply with our policies on slavery, human trafficking, forced
labour and child labour or agree to terms and policies that are
similar to ensure that their principles and practices are aligned with
our expectations and standards.
Robust HR Processes. We have HR and operational processes which
reduce the risk of modern slavery. Our HR function is responsible forall recruitment activities and in doing so follows standard
recruitment procedures. We use reputable employment agencies
and temporary labour agencies in sourcing labour and conduct
appropriate due diligence on any new agency we engage as wellas pre employment screening activities.
Information Classification: General

Speak Up Line. Norstella operates and encourages the use of aconfidential and anonymous Speak Up Line. The hotline is operated
by an independent external service provider, which allows
employees to speak in confidence to someone who is neither anemployee nor their line manager. The external provider reports all
disclosures to the Head of Compliance, who is responsible forensuring that calls are investigated independently from Norstella’smanagement. The hotline is a free-phone telephone number, which
is publicised on Norstella’s intranet and via the Speak Up Policy.
Employees are actively encouraged to report any behaviour
inconsistent with the Code of Conduct or any policy, including any
actual or suspected incidents of modern slavery, via the Speak Up
hotline.
Payment Practices. We understand the correlation between poor
payment practices and modern slavery; therefore we remaincommitted to maintaining fair working relationships with ourvendors at all times. The factors that determine our current
payment periods are our standard terms and conditions or theindividual agreements that we make with vendors.

088%

concerns raised
regarding modernslavery in 2023*at the time of publicationof all employees
completed Codeof conduct
training*9GovernanceCompliance with all Norstella policies including the Code of Conduct is monitored by theAudit Committee to assess effectiveness, this includes the deployment of training and theadequacy for employees to raise concerns in confidence. The Committee reports to theBoard of Directors on these activities. No matters of concern were raised in 2023 in relation tomodern slavery.
This statement is made for the Norstella group of companies with Caerus PIKCO S.A.R.L as its
parent, and applicable subsidiary companies Pharma Intelligence U.K Limited (13787459) andEvaluate Ltd (05876322) in accordance with the requirements of the UK Modern Slavery Act
2015.
Approved by the Board of Directors of Caerus PIKCO S.A.R.L on 30th April 2024.

Michael Gallup - CEO
10Information Classification: General