Modern Slavery Statement

from Liva Healthcare

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I. Introduction

Liva Healthcare maintains a zero-tolerance policy towards modern slavery and human trafficking. We are committed to ethical conduct and integrity in all our operations and relationships. As a pioneer in digital therapeutics, we are deeply committed to upholding human rights and preventing exploitation in any part of our business or supply chain. This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the actions we have taken to ensure that slavery and human trafficking do not take place within our operations or supply chains.

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II. Organisational Structure and Supply Chains

Liva Healthcare, founded in Denmark in 2015, is a leading provider of health services aimed at managing and preventing chronic conditions through behaviour and lifestyle change. We operate primarily in the UK and Nordic countries, delivering services on multiple NHS England frameworks, including the NHS Type 2 Diabetes Path to Remission Programme, National Diabetes Prevention Programme, and Digital Weight Management Programme.

Our supply chain includes:

  • Clinical and digital suppliers;
  • TDR product suppliers (notably Nupo, an EU-regulated medical nutrition provider);
  • Fulfilment and logistics partners for home delivery of nutritional and medicinal products;
  • Technology suppliers providing biometric monitoring devices such as digital scales, blood pressure monitors, and blood glucose monitors;
  • Professional services including legal, HR, and IT support.

III. Policies in Relation to Slavery and Human Trafficking

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We have in place comprehensive corporate policies to prevent modern slavery and human trafficking:

  • Ethical Procurement and Supplier Conduct Policy;
  • Recruitment and Employment Policy;
  • Safeguarding and Whistleblowing Policies;
  • Information Governance and Data Protection Policies;
  • Quality Management System based on ISO 13485 and ISO 27001 standards.

All staff and contractors are expected to uphold our values and comply with our ethical standards.

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IV. Due Diligence Processes

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We undertake due diligence during procurement to ensure our suppliers and partners operate in line with modern slavery legislation. This includes:

  • Requiring assurance of legal compliance in contractual terms;
  • Monitoring of third-party credentials (e.g., Nupo’s compliance with Foods for Special Medical Purposes regulations);
  • Audit and performance oversight procedures embedded in our Quality Management System.

V. Risk Assessment and Management

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We assess our business and supply chains as generally low-risk for modern slavery due to our operational focus in regulated healthcare systems in the UK and EU. However, we recognise potential risk areas:

  • Manufacture and fulfilment of digital health devices sourced through third-party vendors;
  • Logistics and warehousing of TDR products.

We manage these risks through vetting, contractual obligations, and routine oversight of supplier practices.

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VI. Measuring Effectiveness

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To assess the effectiveness of our actions, we monitor:

  • Supplier compliance rates;
  • Internal audit outcomes;
  • Staff completion of mandatory training;
  • Incident reporting and whistleblowing data.

As of May 2026, no instances of slavery or human trafficking have been identified in our business or supply chains.

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VII. Training and Capacity Building

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We provide all employees with training on modern slavery as part of our onboarding and ongoing compliance programmes. This includes:

  • E-learning on the Modern Slavery Act;
  • Modules on safeguarding and ethical conduct;
  • Awareness content highlighting exploitation risks in health-related supply chains.

VIII. Continuous Improvement

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Liva Healthcare is committed to continual review and improvement of its policies and procedures. As part of this, we will:

  • Expand the scope of our supplier assessments;
  • Enhance reporting and monitoring mechanisms;
  • Maintain our alignment with DTAC, NHS DSP Toolkit, and ISO standards.

This statement has been approved by the leadership and will be reviewed and updated annually.

This year, we will be submitting our 2026 Communication on Progress (CoP) to the UN Global Compact focusing on human rights, labour and anti-corruption principles to remain an active signatory. As we continue to grow our business in the US, we will ensure that our business complies with laws and standards in relation to labour practices and human rights worldwide.

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Reviewed:

Kristo Scholtz

Director of Legal, Regulatory, and Compliance

Date: 22 May 2026

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