Modern Slavery Statement

Flok Health Ltd

‍This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps Flok Health Ltd ("Flok Health") has taken to ensure that modern slavery and human trafficking are not taking place in our business or our supply chain. Flok Health has a zero-tolerance approach to modern slavery, servitude, forced or compulsory labour, child labour and human trafficking, and expects the same standard from every organisation we work with.

Flok Health Ltd is a technology-enabled healthcare provider, registered in England and Wales, that designs, builds, and operates autonomous musculoskeletal physiotherapy services. This includes the deployment of a CE-marked Class IIa software medical device diagnostic triage and treatment delivery. All of our employees are UK-based, and all healthcare and special category data are stored and processed in the United Kingdom.

Our supply chain is small and predominantly digital. It consists of cloud infrastructure and software providers, professional advisors (legal, audit, clinical safety, information governance), recruitment and IT equipment suppliers, and NHS partners. The majority of our suppliers are headquartered in the UK, EEA or US.

We maintain policies that set out our commitment to ethical conduct and human rights, including a Code of Conduct, Whistleblowing Policy, Recruitment Policy, Equality, Diversity and Inclusion Policy, Supplier Code of Conduct, and Safeguarding Policy. These policies are reviewed regularly according to an internal audit plan and process, and apply to all employees, contractors and suppliers.

We carry out risk-based due diligence on new and existing suppliers. This includes verifying their legal status, reviewing their own Modern Slavery Statement where applicable, and including modern slavery and ethical conduct clauses in applicable supplier contracts with a right to terminate where we identify a breach. All new joiners complete Right to Work checks in line with UK employment law, and our sub-processor list is reviewed annually as part of our information governance processes.

Our direct workforce is UK-based and salaried, paid at or above the Real Living Wage under contracts that meet or exceed UK employment law. We therefore assess the risk of modern slavery within our direct operations as low. In our supply chain, the areas requiring closest attention are hardware and IT equipment manufacturing (where upstream raw material sourcing can carry higher risk), recruitment and staffing services, and facilities and cleaning services. Where a supplier is assessed as higher risk, we require additional assurance and may decline to onboard or continue with a supplier that cannot provide it.

We measure the effectiveness of our approach through the contractual controls we apply to our supply chain. Before onboarding a higher risk supplier we review their published Modern Slavery Statement (where they are in scope of Section 54) or obtain a written commitment to comply with the Modern Slavery Act 2015, and we include modern slavery and ethical conduct clauses in our applicable supplier contracts with a right to terminate in the event of breach. Suppliers are therefore under a continuing contractual obligation to maintain compliance for the duration of our relationship. During the financial year covered by this statement, we identified no actual or suspected instances of modern slavery within our business or our supply chain.

All Flok Health employees complete induction training that covers our Code of Conduct, whistleblowing arrangements, equality and inclusion, and our anti-slavery commitments. Concerns can be raised in confidence through our internal whistleblowing channel or externally via the Modern Slavery and Exploitation Helpline on 08000 121 700.

This statement was approved by the Directors of Flok Health Ltd and will be reviewed and updated annually.

Finn Stevenson
CEO
Flok Health Ltd
Date: 15 July 2026