Modern Slavery Reporting

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1. Introduction

This statement is made pursuant to the Forced and Child Labour in Supply Chains Act for the reporting period ending 31 December 2023 (Reporting Period) and establishes the steps the reporting entities listed below have taken to assess and address modern slavery risks in its operations and supply chains(Statement).

Reporting Entities and their principal activities

1. Covetrus, Inc., (United States) the holding company of (b through i) below;
2. Jorgen Kruuse A/S, (Denmark) sales of veterinary products;
3. Veterinary Solutions Ltd., (United Kingdom) sales of veterinary products;
4. Veterinary Data Services, Inc., (United States) sales of veterinary technology;
5. VCP, LLC, (United States) sales of veterinary technology;
6. Animal Healthcare Services Ltd., (United Kingdom) sales of veterinary products;
7. HS Veterinary Solutions Ltd., (United Kingdom) sales of veterinary technology;
8. SmartPak Equine, LLC, (United States) sales of animal nutritionals; and
9. Provet NSW Pty Ltd., (Australia) sales of veterinary products.

2. Organizational Structure and Operations

Covetrus is a privately held global animal health technology and services company dedicated to empowering veterinary practice partners to drive improved health and financial outcomes.

Founded in February 2019 through the merger of Vets First Choice and Henry Schein Animal Health, Covetrus brings together products, services, and technology into a single platform that connects customers to the solutions and insights they need to work best. Covetrus’ passion for the well-being of animals and those who care for them drives us to advance the world of veterinary medicine. Covetrus is headquartered in Portland, Maine (USA), with more than 6,000 employees, serving over 100,000 customers around the globe.

The vision of Covetrus has always been to be more than a veterinary distributor but rather a company that provides added value to veterinary practices to help them build better businesses. The outstanding service and value-added business solutions that differentiate Covetrus include:

• A comprehensive product offering at highly competitive prices for small, large, and equine animal practices including biologicals, diagnostics, nutritionals, parasiticides, pharmaceuticals, disposables, and more
• Our range of exclusively distributed products, offering affordable value
• Innovative technology solutions including inventory management, practice management software, and websites
• Training and consulting for veterinarians, practice managers, and veterinary nurses

3. Supply Chain

Covetrus, Inc. and its subsidiaries have over 1000 active suppliers for animal healthcare products, many of which have long-standing relationships and therefore have clear expectations regarding compliance and social accountability.

All Covetrus entities manage external vendor relationships through two channels – direct and indirect suppliers. The majority of the company’s suppliers are based in the region corresponding to each subsidiary, with few imports from outside regions. All goods purchased for resale are classified as direct suppliers, and indirect goods and services procured externally are included as indirect suppliers, for example, logistics, marketing, IT, etc.

During the Reporting Period, Covetrus and its subsidiaries had suppliers from the following industries:

• Pharmaceuticals
• Nutraceuticals
• Nutrition (wet and dry pet food) and supplements
• Medical and surgical equipment and consumables
• Veterinary merchandise
• Stationery
• Equipment
• Electronics – IT hardware and software
• Logistics
• Food and beverage
• Utilities
• Marketing
• Professional services
• Facilities maintenance including cleaning

4. Modern Slavery Risks

Modern slavery risks in our operations

The risk of modern slavery occurring within the Covetrus, Inc., operations and/or its subsidiaries or affiliates are considered low based on the following:

• The United States, Denmark, United Kingdom, and Australia have low risks of modernslavery according to the Global Slavery Index (GSI);
• There is a high degree of compliance and regulatory oversight regarding workplace lawsin the jurisdictions of each country mentioned above;
• There are policies and procedures in place to address vendor oversight at onboarding, and targeted trainings for employees.

Modern slavery risks in our supply chain

Most of our direct and indirect goods and services are supplied from the countries in which each entity operates, which are considered to have a low prevalence for modern slavery risk according to the GSI. The majority of the products we source are from heavily regulated industries, which may also mitigate the risk of modern slavery.

However, we recognize that there are inherent risks of modern slavery occurring within the products we, and our owned or controlled entities, procure due to a combination of industry, geography, and product type. Examples are:

• Products manufactured in high-risk countries specific to the healthcare sector (e.g. surgical and examination gloves, surgical instruments) and general veterinary consumables and merchandise (e.g. point of sale items, promotional materials, toys, collars, harnesses, leashes, etc).
• Labor risks associated with sourcing raw materials including cotton, rubber, nylon, metals and minerals, and agricultural supplies
• Packaging materials including pallets, boxes, paper, and paper components
• Technology hardware and support services
• Shipping and logistics

Risks may also exist in the operations of suppliers in higher-risk services such as facilities maintenance including cleaning, chauffeur services, and courier services. We are aware of the existence of these risks based on publications regarding modern slavery risks in certain sectors.

There have been no reports of actual or suspected modern slavery brought to our attention in respect of our supply chains.

5. Actions taken to assess and address modern slavery risks in our operations and supply chain

Our policies

We take modern slavery and human trafficking very seriously and we are committed to maintaining the highest level of integrity, ethical standards, and legal principles in every aspect of our business. We have a number of policies and procedures in place to uphold this commitment. All employees within Covetrus, Inc., and its entities are required to undergo yearly training on forced and child labor via way of web-based or in-person modules that review the topic, company policies, and remediation processes. In addition, we evaluate employees each year to determine if or when additional trainings may be required.

Code of Business Conduct and Ethics (Code)

Our Code requires all employees, executive officers, directors, and other third parties acting on behalf of the company to comply with all laws, rules, and regulations. The Code also reaffirms our commitment to equal employment opportunities for our employees, to providing a workplace that is free from discrimination and harassment, and to maintaining a workplace that is safe and healthy. Additionally, the Code is regularly reviewed to address any required legal, regulatory or language updates.

Supplier Code of Conduct (Supplier Code)

We expect our suppliers to conduct their business lawfully and in compliance with the highest standards of integrity and ethics. Our Supplier Code sets out our expectations of suppliers in relation to human rights. It requires suppliers to maintain and promote fundamental human rights and ensure they provide an environment where employment decisions are based on free choice and do not involve forced or prison labor, physical punishment or threats of violence, or other forms of physical, sexual, psychological, or verbal abuse as a method of discipline or control. The Supplier Code also prohibits child labor and demands adherence to the minimum employment age limit as defined by applicable laws.

Remediation

Our employees are encouraged to report any known or suspected violations of law, regulation, or policy via the reporting mechanisms set out in the Code. Grievances can also be raised via our Ethics & Compliance Line (Hotline) and are accessible on our website by employees, suppliers, customers, and other stakeholders. The Hotline is operated by an independent third party, and is available worldwide 24 hours a day, 7 days of week, via telephone and the internet. Reports can be made anonymously, where permitted by local law. We also have in place additional policies and procedures to protect whistleblowers, including a non-retaliation policy. No reports were received during 2023 that raised concerns in relation to modern slavery.

In the event that our business is found to have caused or contributed to an actual instance of modern slavery, our immediate priority would be the safety and well-being of the victim. Specific remediation activities would be determined on a case-by-case basis to ensure the most appropriate and effective actions are undertaken.

During the reporting period, based on the lack of reporting of specific incidents, Covetrus did not take measures to remediate the loss of income to the most vulnerable families related to the use of forced labor or child labor.

Supply chain

Each supplier is provided a copy of Covetrus’ Supplier Code and is asked to confirm in writing their adherence to the principles in the Supplier Code. Covetrus, Inc. and its subsidiaries conduct an annual risk review of existing suppliers based on country and category risk. We also conduct a third-party due diligence assessment of suppliers based on each company’s risk profile.

During the Reporting Period, Covetrus, Inc. and its subsidiaries also conducted a supplier modern slavery risk assessment. The risk rating provided to each supplier was informed by a number of factors and datasets, including industry type, geographical location from which the goods or services are procured, sector risk, and consideration of the extent of our visibility over specific vendor supply chains. In the process, we identified no high-risk vendors.

6. Assessing the effectiveness of our actions

Covetrus, Inc. and its entities are committed to achieving year-on-year improvement in our approach to assessing and addressing modern slavery risks in our operations and supply chains. We will seek to assess the effectiveness of our overall approach by tracking the progress of the following ongoing goals during the second reporting period:

• We will review and update existing policies and procedures, as appropriate, to reinforce our zero-tolerance for slavery and human trafficking;
• We will review whistle-blower reports to assess if they reflect any modern slavery risk in our operations or supply chains;
• We will review and revise supply chain contracts as needed to examine and adapt the organization’s supply chain contracts to include prohibitions on the use of forced labor and child labor.
• We will seek to obtain a deeper understanding of the modern slavery risks beyond the first tier of our supply chain; and
• We will seek to raise awareness of modern slavery within our workforce.

7. Consultation and approval

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.

• Tamika S. Simmons
• Vice President, Chief Regulatory and Compliance Officer
• May 21, 2024