Modern Slavery Agreement

Policy Statement

Introduction

This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It
constitutes Peppy Health Limited’s (Peppy) slavery and human trafficking
statement for the financial year ended 2023.

Our Organisation

Peppy delivers benefits that employees love. We work with leading healthcare
practitioner organisations, expert practitioners and the world’s best companies to
improve the health and wellbeing of employees going through major life
transitions.

Our staff are largely based in the UK and directly employed. They are generally
not in any category which is seen to be vulnerable to modern slavery in this
country, so our main focus is to ensure there are policies and due diligence
procedures in place for our suppliers.

Our Supply Chain

Peppy is committed to continuously improving its practices to identify and
eliminate any slavery and human trafficking in its business and supply chains,
and to acting ethically and with integrity in all its business relationships.

Most of Peppy’s suppliers are global technology organisations.

Policies

Peppy has a number of policies which underpin our approach to tackling the risk
of modern slavery in our supply chain. These include:

  • Code of Conduct which sets out the ethical expectations of all Peppy
    employees;
  • Whistleblowing Policy which is an anonymous reporting channel to report
    violations of information security – "whistleblowing". encourages staff and
    volunteers to report concerns including any related to modern slavery/trafficking
    and child or forced labour.

Additionally, we consider risks related to modern slavery/trafficking as part of our
information security assessments (part of our ISO27001 compliance).

Due Diligence

We monitor suppliers we believe present high modern slavery risks in our supply
chain.

All suppliers which we class as high risk must:

  • complete our Modern Slavery Act Due Diligence Questionnaire which
    covers their governance, policies, training, supply chain management
    processes; and
  • on an annual basis and prior to sourcing, provide full detail of the supply
    chains they are proposing to commission goods from on behalf of Peppy.

A Peppy team is responsible for assessing the information submitted by suppliers
where applicable. Should a supplier fail to provide the information requested or to
meet Peppy’s expectations, Peppy will take appropriate action. For example, this
may include not entering into a relationship or suspending/terminating our
relationship with a supplier.

Training

We provide advice and guidance to individuals with direct responsibility for
relevant supply chains. We distribute this statement to all staff on an annual.

Looking Ahead

As we grow we will continue to enhance our procedures to help us identify,
prevent and mitigate any risks of modern slavery or human trafficking in relation
to new and existing suppliers and in relation to our own operations.

Approval

This statement has been formally approved by the Directors of Peppy Health
Limited and signed on their behalf.

This policy will be reviewed annually by the CEO who will take responsibility for
implementing this policy statement to ensure that our organisation and supply
chains are free of slavery and human trafficking.