Introduction

At Delve Health, we are committed to upholding human rights and ethical practices throughout our operations and supply chains. We recognize the existence of modern slavery, a grave violation of human rights, and we are determined to prevent any form of forced labor, human trafficking or exploitation within our business and supply networks. This Modern Slavery Statement outlines our commitment, policies and actions taken to combat modern slavery and ensure the well-being of all individuals involved in our business activities.

Our Organization

Delve Health is a dynamic and innovative company operating at the intersection of clinical research and healthcare. Our core activities revolve around leveraging advanced technologies and data analytics to accelerate medical discoveries, optimize clinical trials and enhance patient care. We operate around the world and are fully aware of our responsibility to respect and protect human rights in all jurisdictions we operate within. We strive to create an environment that fosters dignity, equality and respect for everyone—including employees, contractors, suppliers and the communities in which we serve.

Our Policies and Commitments

Zero-Tolerance: We have a zero-tolerance approach to modern slavery in all its forms. We prohibit forced labor, human trafficking, child labor and any other exploitation. We expect our employees, contractors, and suppliers to adhere to the same high standards.

Compliance: We comply with all applicable laws and regulations related to modern slavery in every country where we operate. Our commitment extends to international standards, including the International Labour Organization’s (ILO) core conventions and the United Nations Guiding Principles on Business and Human Rights (UNGPs).

Risk Assessment

We conduct regular risk assessments across our operations and supply chains to identify areas where modern slavery risks may exist. This includes assessing the risk profile of our suppliers, geographic locations and industry sectors.

Supplier Due Diligence

We have implemented a robust supplier due-diligence process to ensure that all our suppliers share our commitment to eradicating modern slavery. This includes conducting assessments, audits and monitoring activities to verify compliance with our standards.

Supplier Code of Conduct

We have established a Supplier Code of Conduct that outlines our expectations regarding human rights, labor practices and ethical behavior. We routinely communicate these expectations to our suppliers and require their commitment to adhere to these principles.

Employee Training

We provide comprehensive training to our employees, particularly those involved in procurement and supply chain management, to raise awareness about modern slavery risks, identify indicators and report any concerns or suspicions.

Reporting Mechanisms

We have implemented reporting mechanisms to encourage individuals, both within and outside our organization, to report any suspicions or incidents related to modern slavery. These channels ensure confidentiality and non-retaliation for whistleblowers

Continuous Improvement

We are committed to continuously improving our efforts to combat modern slavery. We regularly review and update our policies, procedures and practices to align with evolving best practices and emerging risks.

Our Future Actions

In our ongoing commitment to combat modern slavery, we will enhance transparency by continuing to increase transparency within our supply chains, providing clear visibility into our sourcing practices and the steps we take to ensure ethical conduct.

Collaboration

We will collaborate with industry peers, governments, NGOs and other stakeholders to share knowledge, best practices and resources in our collective efforts to eradicate modern slavery.

Supply Chain Engagement

We will work closely with our suppliers, supporting them in improving their labor practices, promoting fair wages and providing training on human rights and ethical conduct.

Independent Audits

We will conduct independent audits, both internally and externally, to assess compliance with our policies and identify areas for improvement within our operations and supply chains.

Conclusion

At Delve Health, we are committed to combating modern slavery in all its forms. We will not tolerate any practices that compromise the rights and dignity of any individuals, anywhere in the world. This Modern Slavery Statement reflects our dedication to transparency, accountability and continuous improvement.