Modern Slavery and Ethical Supply Chain Statement

LoHA Health Ltd (“LOHA”) is a micro-sized company providing software, skills and training that support parents and carers in helping young people with their mental health. The technology can be directly by parents or carers or under the supervision of a trained health or social care professional.

We recognise that modern slavery, human trafficking, forced labour and exploitation are serious violations of human rights. We are committed to conducting our business ethically and responsibly and have a zero-tolerance approach to modern slavery and human trafficking within our business and supply chain.

As a micro-SME, our approach is proportionate to the size and nature of our organisation and the relatively limited complexity of our supply chain. We nevertheless recognise that modern slavery risks can exist within technology supply chains, including through third-party service providers, contractors, cloud and technology providers, hardware suppliers and other outsourced services.

1. Organisation and Supply Chain

LOHA is a micro-SME with a straightforward organisational structure. Responsibility for ethical business practices and supply-chain management sits with our CEO / Founder Alison Metcalfe, who has overall oversight of our approach to modern slavery and responsible procurement.

Our supply chain primarily consists of suppliers and service providers supporting our digital technology activities, which may include:

• software and cloud-based technology providers;
• IT and telecommunications providers;
• professional and specialist contractors;
• hardware and equipment suppliers, where applicable;
• business and professional services; and
• other outsourced services necessary to operate our business.

We do not operate manufacturing facilities or employ a large, geographically dispersed workforce. We consider the principal modern slavery risks in our supply chain to arise indirectly through third-party suppliers and, where relevant, their own supply chains.

2. Policy and Zero-Tolerance Approach

We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, child labour and other forms of labour exploitation.

We expect our employees, contractors, suppliers and business partners to conduct themselves ethically and in accordance with applicable laws and internationally recognised principles relating to human rights and labour standards.

Our approach is supported by our wider commitment to:

• ethical and responsible business practices;
• fair treatment of workers;
• compliance with applicable employment and labour laws;
• responsible procurement;
• openness and transparency; and
• raising concerns where unethical or potentially exploitative practices are identified.

Where appropriate, our expectations are communicated to suppliers as part of our procurement and supplier-management processes.

3. Supplier Due Diligence

We undertake proportionate due diligence when appointing and reviewing suppliers.

Depending on the nature and risk associated with a supplier, this may include:

• considering the supplier's location, services and supply-chain characteristics;
• reviewing relevant policies, certifications or publicly available information;
• asking suppliers to confirm their commitment to preventing modern slavery and unethical labour practices;
• considering relevant contractual terms and requirements;
• assessing whether the supplier presents any identifiable modern slavery or ethical-supply-chain concerns; and
• conducting additional enquiries where a particular risk or concern is identified.

The level of due diligence is proportionate to the size, nature and risk of the supplier relationship. Higher-risk suppliers or arrangements may be subject to additional scrutiny.

4. Risk Assessment and Management

We periodically consider modern slavery risks within our own operations and supply chain as part of our wider business and supplier-risk management.

Our assessment takes account of factors such as:

• the type of goods or services being supplied;
• the location and nature of the supplier's operations;
• the use of subcontractors or outsourced labour, where known;
• the complexity of the relevant supply chain;
• the potential vulnerability of workers; and
• any concerns, allegations or adverse information identified.

Where a risk is identified, we will assess its seriousness and determine an appropriate response. This may include seeking further information or assurances, agreeing remedial actions, increasing monitoring, or reconsidering the supplier relationship.

We recognise that effective modern-slavery management is an ongoing process and that risks can change over time.

5. Reporting Concerns and Remediation

We encourage employees, contractors and relevant third parties to raise concerns about suspected unethical conduct or modern slavery.

Any concern raised will be taken seriously and reviewed appropriately. Where an actual or potential instance of modern slavery or exploitation is identified within our operations or supply chain, we will take appropriate action based on the circumstances, which may include further investigation, engagement with the relevant supplier, corrective or remedial action, and escalation to the appropriate authorities where necessary.

We will not knowingly continue a supplier relationship where a supplier is unwilling to address serious modern slavery concerns appropriately.

6. Effectiveness and Review

Given our size and straightforward supply-chain structure, we use proportionate measures to monitor the effectiveness of our approach.

These include:

• maintaining appropriate records of supplier due diligence;
• reviewing identified supplier risks;
• monitoring concerns or incidents raised;
• considering compliance with our supplier expectations;
• reviewing our policies and procedures periodically; and
• considering whether additional controls or training are required as our business and supply chain develop.

We review this statement and our approach to modern slavery annually, and sooner where there are significant changes to our business, supply chain or identified risks.

Our aim is to continually improve our approach rather than simply relying on contractual or policy commitments.

7. Staff Awareness and Training

We ensure that relevant staff are aware of our zero-tolerance approach to modern slavery and understand how to recognise and report concerns.

As a micro-SME, training is proportionate to our size and the roles within the business. Relevant employees receive appropriate awareness information and, where their responsibilities require it, additional guidance on ethical procurement, supplier due diligence and identifying potential exploitation.

Training and awareness materials are reviewed when the business scales to ensure they remain relevant to our business and emerging risks.

8. Responsibility and Approval

Overall responsibility for implementing and reviewing this statement rests with CEO / Founder Alison Metcalfe

This statement is reviewed annually and has been approved by the management of LOHA Health Ltd.

Approved by: Alison Metcalfe
Position: CEO / Founder
Date: 19^th August 2026
Next review date: 19^th August 2027

Our commitment

LOHA is committed to maintaining a business and supply chain in which modern slavery, human trafficking and exploitation have no place. We will continue to take practical, proportionate and risk-based steps to identify, prevent and address these risks as our organisation and supply chain develop.