Anti-Modern Slavery Statement

For the Fiscal Year ending December 31, 2024  

Introduction

Modern Health maintains a zero-tolerance stance on all forms of modern slavery, whether within our own operations or our supply chain.  

This Modern Slavery Statement ("this Statement”) is made in accordance with the United Kingdom’s Modern Slavery Act, 2015 and Australia’s Modern Slavery Act, 2018  and outlines the measures taken by Modern Health to prevent modern slavery and human trafficking within its business and supply chains for the year ending December 31, 2024.  

This Statement also reflects our commitment to: (i) act ethically and with integrity in all our business relationships; and (ii) implement and enforce effective systems and controls to preclude modern slavery, in any form, taking place anywhere in our business or in our supply chains.

Structure, Operations, and Supply Chains

Modern Health is a leading mental health technology company, providing comprehensive, evidence-based, and equitable mental health care solutions to employers who offer such services to their employees and families worldwide.  

Modern Health’s services include clinical therapy, psychiatry, coaching, and self-guided digital programs.  As a result, our supply chain consists primarily of (a) the professional services of mental health providers and (b) technology services. We partner with such providers and technology service vendors (“Suppliers”) that agree to follow our Code of Conduct, ensuring they share our values and uphold the principles of integrity that are central to our operations.

Risk of Modern Slavery in our Operations and Supply Chains  

Given the nature of Modern Health’s business as a digital mental health service provider, we believe the risk of human trafficking or modern slavery in our business or supply chain is very low. Our digital service model minimizes reliance on physical goods and labor- intensive operations, further reducing exposure to modern slavery risk.  

However, Modern Health adopts a proactive approach to remain alert to the risks of modern slavery.

Policies and Controls

Modern Health mitigates the risk of modern slavery and human trafficking in several ways, including:  

• Code of Conduct:  Modern Health’s Code of Conduct sets expectations and responsibilities for all employees and Suppliers to maintain ethical behavior in all business dealings. We expect all employees and Suppliers to report any concerns through the designated reporting channels and are committed to thoroughly investigating and addressing any allegations of human rights violations. All employees are also required to consent to abide by the Code of Conduct upon hire, and on an annual basis thereafter.

• Employee Handbook: Both the Code of Conduct and the Employee Handbook affirm our commitment to a respectful work environment, free from violence, threats or other acts of aggression.
• Multiple Reporting Channels: Modern Health provides several avenues for reporting concerns, including the Modern Health Integrity Line, with options for anonymous reporting. The Modern Health Speak up Policy establishes procedures for all employees or third parties to report legal and ethical violations. We promote these reporting options through our internal policies, regular communications, and mandatory annual compliance training.
• Supplier Due Diligence: We conduct due diligence on our Suppliers to ensure they comply with applicable laws, regulations, and our Company policies and standards.
• Training and Awareness: We provide training to our employees and certain Suppliers to ensure compliance with applicable laws, regulations, and our Company policies and standards.  
• Commitment to the UN Global Compact:  As outlined in our Code of Conduct, Modern Health is committed to incorporating the ten principles of the UN Global Compact into our business  strategies and policies and procedures–which includes preventing modern slavery in any form.

Modern Health is committed to ethical practices and promotes a culture of integrity. We maintain the highest ethical standards and comply with all laws, rules, and regulations that apply to our business.  

Assessment of Effectiveness  
Modern Health is committed to continuous improvement in our efforts to combat modern slavery. We will review and update our policies and practices regularly to ensure they remain effective and aligned with best practices.  

Review and Approval
‍This statement will be reviewed and updated where required on an annual basis. This statement has been approved by the Board of Directors of Modern Life, Inc.  

Alyson Watson
CEO and Founder of Modern Health

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