Modern Slavery Statement

Introduction

At Delve Health, we are committed to upholding human rights and ethical practices throughout our operations and supply chains. We recognize modern slavery as a grave violation of human rights and are determined to prevent any form of forced labor, human trafficking, child labor, or exploitation within our business and supplier networks.

Our Organization

Delve Health operates at the intersection of clinical research and healthcare, delivering technology and services that support global clinical trials and patient-centered research. We operate internationally and recognize our responsibility to respect and protect human rights in every jurisdiction in which we operate.

We strive to foster a culture of dignity, equality, and respect for all — including employees, contractors, suppliers, and the communities we serve.

Our Policies and Commitments

• Zero-Tolerance: We prohibit all forms of forced labor, human trafficking, child labor, and exploitation.
• Legal Compliance: We comply with all applicable modern slavery laws in the jurisdictions in which we operate.
• International Standards: Our practices align with the International Labour Organization (ILO) core conventions and the UN Guiding Principles on Business and Human Rights (UNGPs).

Risk Assessment

We conduct regular risk assessments across our operations and supply chains to identify potential modern slavery risks. This includes evaluating geographic, sector-specific, and supplier-level risk factors.

Supplier Due Diligence

Delve Health maintains a supplier due-diligence framework designed to ensure our partners uphold ethical labor practices. This includes assessments, monitoring, and compliance verification where appropriate.

Supplier Code of Conduct

Our Supplier Code of Conduct outlines expectations related to human rights, working conditions, labor practices, and ethical behavior. Suppliers are expected to acknowledge and comply with these standards.

Employee Training

We provide training to employees involved in procurement, operations, and vendor management to raise awareness of modern slavery risks and empower them to identify and report concerns.

Reporting Mechanisms

Delve Health maintains reporting channels that allow individuals — internal or external — to raise concerns related to modern slavery confidentially and without fear of retaliation.

Continuous Improvement

We regularly review and strengthen our policies, procedures, and controls to reflect evolving best practices and emerging risks.

Our Future Actions

• Increase transparency across our supply chains
• Engage suppliers to improve labor practices and awareness
• Collaborate with industry peers, NGOs, and regulators
• Conduct independent audits where appropriate

Conclusion

Delve Health will not tolerate practices that compromise human dignity or rights. This Modern Slavery Statement reflects our commitment to transparency, accountability, and continuous improvement in preventing modern slavery in all its forms.