Modern Slavery & Human Trafficking Statement

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out
the steps taken by Thriving.ai Ltd and its associated group entities to prevent modern slavery
and human trafficking in its business operations and supply chains.

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a) Organisation Structure, Business and Supply Chains
Thriving.ai Ltd is a digital health and technology company focused on supporting healthy ageing
and community-based care through software platforms and data-driven insights. The
organisation operates primarily in the UK, with related entities and activities in Canada and the
United States. Thriving.ai’s supply chains are limited in scope and consist mainly of professional
services, software development, cloud hosting, research partnerships, and consultancy providers.
The company does not operate in high-risk manufacturing, agriculture, or extractive sectors.

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b) Policies on Slavery and Human Trafficking
Thriving.ai has a zero-tolerance approach to modern slavery and human trafficking. The
company is committed to acting ethically and with integrity in all business relationships and
expects the same standards from suppliers, partners, and contractors. This commitment is
reflected in contractual terms, supplier onboarding practices, and internal governance standards.

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c) Due Diligence Processes
Thriving.ai undertakes proportionate due diligence when engaging suppliers and partners. This
includes risk-based assessment of supplier location, sector, and service type, confirmation of
legal compliance, and contractual requirements to adhere to labour and employment laws. Where
appropriate, suppliers are required to confirm their compliance with modern slavery legislation
and ethical labour practices.

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d) Risk Assessment and Management
Given the nature of Thriving.ai’s operations, the risk of modern slavery within its direct business
is considered low. Potential risk areas are limited to indirect supply chains such as outsourced
technology services or overseas contractors. To manage this risk, Thriving.ai prioritises suppliers
based in low-risk jurisdictions, engages reputable service providers, and reviews supplier
practices where concerns are identified.

www.thriving.ai
E-mail: shain@thriving.ai

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e) Effectiveness and Performance Indicators
Thriving.ai monitors effectiveness through:
- supplier screening and contract reviews
- absence of reported incidents or concerns related to modern slavery
- regular review of supplier relationships
Any identified issues would be escalated to senior leadership and addressed promptly.

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f) Training and Capacity Building
Thriving.ai ensures that staff and leadership are aware of modern slavery risks and
responsibilities through onboarding, internal policies, and access to relevant guidance. As the
organisation grows, it will continue to strengthen training and awareness proportionate to its size
and risk profile.

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Approval and Review
This statement has been approved by the Board of Thriving.ai Ltd and will be reviewed annually.
Signed:
Shain Khoja
Founder & CEO
Thriving.ai Ltd
Date: 01012026