2022/2023 Modern Slavery and Human Trafficking Statement

The Modern Slavery Act 2015 requires those entities carrying on a business or part of a business in the UK, supplying goods or services, and having an annual turnover of £36 million or more to disclose information regarding the steps they have taken to eradicate slavery and human trafficking from their supply chain as well as within their own organisation during the previous financial year.

Contents of this Policy:

• Introduction
• Organisation's structure
• Our business
• Our supply chains
• Our policies on slavery and human trafficking
• Due diligence processes for slavery and human trafficking
• Training
• Our effectiveness in combating slavery and human trafficking

1. Introduction

At Thriva Limited (“Thriva”) we are working hard to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This statement highlights the key activities we have undertaken during this financial year to combat modern slavery in our organisation and supply chain.

As this is the first year that we are required to produce a statement, we have worked hard to identify the key areas to prioritise and we will be adding to these over the coming year.

2. Organisation's structure

We are a health technology company based in London, United Kingdom and we operate across the wellness sector. We have over 121 employees in the United Kingdom, and we currently do not have any international offices or subsidiaries.

3. Our business

Our business is organised into two business units: direct to consumer and indirect to consumer. Direct to consumer (B2C) makes bio-marker data accessible, intuitive and linked to personalised, engaging and actionable health recommendations. Indirect to consumer (B2B) is a flexible turn-key remote diagnostics solution for a range of healthcare providers such as hospitals, insurers, specialist commercial companies and telemed.

4. Our supply chains

Our tier 1 suppliers (defined as those that together deliver over 80% of our goods and services) have appropriate contractual terms in place to combat modern slavery. In addition, our key suppliers are regulated manufacturers and distributors of medical devices and pharmaceutical products and our key service providers are based in the United Kingdom.

We have some smaller suppliers that are located in countries that may be more vulnerable to human rights abuses than others and we are working to strengthen our supplier due diligence and onboarding processes for all renewals and new supply agreements to account for risks in lower tier suppliers or indirect supply chain.

5. Our policies on slavery and human trafficking

We have implemented appropriate policies that underpin our commitment to ensure that there is no modern slavery or human trafficking in our business and in our supply chains. As our business grows, we are reviewing and updating our policies to provide more robust and extensive coverage.

Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

6. Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we are implementing and refreshing existing systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistleblowers.
• Train our staff to have a high level of understanding of modern slavery and human trafficking risks in our supply chain and in our business.

7. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will be providing additional training to our employees that work directly with suppliers and procurement. This is in addition to our company wide policies and guidance that is currently available to all our staff.

8. Our effectiveness in combating slavery and human trafficking

We have a risk register and risk committee for the purpose of monitoring risks to our business and risks relating to modern slavery and human trafficking in our supply chain have been added to these functions for ongoing review.

We are working on key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply. We intended to report on the progress in respect of our KPIs in our second annual statement.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2021. It was approved by the board on 21 November 2022.