Last updated: 5th May 2026

1. Policy Statement

Modern slavery is a serious crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced or compulsory labour, and human trafficking, all of which involve the exploitation of individuals for personal or commercial gain.

Welcome Health Ventures Ltd (“WHV”, “we”, “us”, “our”) has a zero-tolerance approach to modern slavery. We are committed to acting ethically, with integrity, and with transparency in all our business dealings and relationships.

We are dedicated to implementing and maintaining effective systems and controls to ensure that modern slavery is not taking place:

  • Within our own operations
  • Within our supply chains
  • Within the activities of our partners and associated organisations

2. Scope

This policy applies to all individuals working for or on behalf of WHV, including:

  • Employees (if applicable)
  • Directors and officers
  • Contractors and consultants
  • Advisors and associates
  • Agency workers and freelancers
  • Third-party representatives and partners

This policy does not form part of any contract of employment and may be updated at any time.

3. Our Commitment

We are committed to:

  • Conducting business with integrity and accountability
  • Maintaining transparency in our operations and supply chains
  • Working only with organisations that share our ethical standards
  • Preventing exploitation in any form across our ecosystem

We expect all suppliers, contractors, and business partners to:

  • Prohibit the use of forced, compulsory, or trafficked labour
  • Ensure no individuals are held in slavery or servitude
  • Apply equivalent standards within their own supply chains

4. Responsibility and Governance

Overall responsibility for this policy sits with the Leadership of WHV.

The CEO and senior leadership team are responsible for:

  • Ensuring compliance with legal and ethical obligations
  • Monitoring the effectiveness of this policy
  • Addressing any concerns or breaches
  • Ensuring appropriate due diligence is carried out where required

All individuals working with WHV are responsible for:

  • Understanding and complying with this policy
  • Acting in accordance with its principles
  • Raising concerns where appropriate

5. Compliance and Reporting

The prevention, detection, and reporting of modern slavery is the responsibility of everyone working with or on behalf of WHV.

All individuals must:

  • Avoid any activity that could lead to, or suggest, a breach of this policy
  • Remain vigilant to risks within our business and supply chains

If you believe or suspect that modern slavery may be taking place, you must report it as soon as possible to:

  • A WHV director or senior contact
  • Or via any appropriate reporting channel

Concerns should be raised at the earliest opportunity, even where there is uncertainty.

6. Protection for Whistleblowers

We are committed to fostering a culture of openness.

WHV will:

  • Support anyone who raises genuine concerns in good faith
  • Ensure that no individual suffers any detrimental treatment as a result of reporting concerns

If you believe you have been treated unfairly after raising a concern, this should be reported immediately to senior leadership.

7. Due Diligence and Supply Chain Management

While WHV operates as a lean advisory and venture-building organisation, we take reasonable steps to:

  • Assess the ethical standards of key partners and suppliers
  • Prioritise working with reputable organisations
  • Avoid engagement with entities where there are credible risks of exploitation

Where appropriate, we may:

  • Include contractual provisions relating to modern slavery
  • Seek assurances from partners regarding compliance
  • Discontinue relationships where standards are not met

8. Communication and Awareness

This policy is communicated to all relevant stakeholders, including:

  • Employees and associates
  • Contractors and partners

We will reinforce our zero-tolerance approach:

  • At the outset of business relationships
  • During ongoing engagements where appropriate

Training will be provided where necessary, proportionate to the nature of the engagement.

9. Breaches of This Policy

Any breach of this policy is taken seriously.

  • Employees or contractors may face disciplinary action, including termination
  • WHV may terminate relationships with partners, suppliers, or third parties who fail to meet these standards

10. Continuous Improvement

WHV is committed to continuously reviewing and improving its approach to:

  • Ethical business conduct
  • Supply chain transparency
  • Risk awareness relating to modern slavery