UK Modern Slavery Act

Introduction

Waters Corporation (“the Company”) takes an unequivocal zero-tolerance approach to modern slavery and human trafficking in all its forms. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps Waters Corporation has taken during the financial year ending 31 December 2025 to ensure that slavery and human trafficking are not taking place in our business or supply chains.

Waters is committed to acting ethically and with integrity across all our business activities and to implementing and enforcing effective systems and controls to safeguard against any form of modern slavery.

Organization Structure and Supply Chains

Waters Corporation is a global leader in the design, manufacture, and sale of analytical instruments, associated software, consumables, and services. Waters operates in the United Kingdom through two principal subsidiaries:

• Micromass UK Limited – which primarily supports the design, manufacture, and sale of mass spectrometry instruments, accompanying software, chemicals, and spare parts; and
• Waters Limited – which conducts sales, support, and marketing of analytical instruments, associated chemicals, and software for customers across the United Kingdom.

Waters operates a global supply chain that spans multiple geographies and sectors. Our direct supply base comprises suppliers providing raw materials, electronic components, precision-engineered parts, chemicals, and professional services. We recognize that supply chain complexity, particularly at sub-tier level, can give rise to heightened risks of labor exploitation and modern slavery, and we continue to strengthen our oversight accordingly.

Policies in Relation to Slavery and Human Trafficking

Waters maintains a suite of policies and standards that establish our expectations with respect to human rights and ethical conduct. These include

• Supplier Code of Conduct – which sets out Waters’ minimum expectations for suppliers in relation to labor rights, safe working conditions, fair wages, and the prohibition of child and forced labor.
• Supplier Terms and Conditions – which incorporate our ethical sourcing requirements and reserve the right to terminate relationships with suppliers that fail to meet applicable legal or ethical standards.
• Whistleblowing Policy – which provides all employees, contractors, and third-party business partners with accessible and confidential channels to report actual or suspected violations of law or Company policy, free from any risk of retaliation.

These policies are reviewed on a periodic basis and are made available to relevant personnel. Our Supplier Code of Conduct is communicated to suppliers as part of the onboarding process and is embedded in our standard contractual terms.

Due Diligence Process

Waters maintains rigorous supplier oversight through comprehensive audits and engagement metrics. Our quality engineers audit critical suppliers to verify safety and product quality, following guidance from the Pharmaceutical Supply Chain Initiative. Audits reflect each supplier’s specific business operations.

We track key supplier engagement metrics, including service responsiveness, impact, sourcing, delivery timing, and overall risk. Through scorecards and periodic supplier reviews, we discuss engagement metrics, strategic objectives, and service improvement opportunities. As part of supplier monitoring, we look for safeguards such as a documented human rights policy, implementation of a supply chain code of conduct, and active sustainability efforts. Our evaluation also includes a review of their participation in our annual Conflict Minerals Survey. Our expectations are systematically reinforced through procurement contracts, supplier onboarding, and our Supplier Code of Conduct. This ongoing dialogue allows us to identify and address challenges and align supplier operations with long-term goals.

Our supplier evaluation process begins with comprehensive due diligence on prospective partners. We screen for environmental and social factors; conduct negative media checks; and visit sites to verify alignment with our core values and operational requirements. Only after completion of these evaluations do we finalize contracts or extend partnerships. We reserve the right to terminate any relationship that does not meet our ethical, legal, and operational standards.

Further Information

We remain committed to contributing to a more sustainable future by accelerating the benefits of pioneering science for customers and communities around the world. You can read more about our sustainability activities in our annual sustainability report, which can be found here:
https://www.waters.com/nextgen/global/about-waters/environmental-social-and-governance.html

Conclusion

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and is applicable to Waters’ financial year ending 31 December 2025.

Signed, May 21, 2026.