Modern Slavery and Human Trafficking Statement

Financial year prediction ending 31 December 2026 | Alto Health Limited (Ireland, CRO 753717) and Alto Health UK Ltd (Northern Ireland, NI724606)

Introduction

This statement sets out the steps Alto Health has taken to understand and reduce the risk of modern slavery and human trafficking in its own business and its supply chains. It covers Alto Health Limited and Alto Health UK Ltd (together, "Alto", "we").

Neither company is currently required to publish a statement under section 54 of the Modern Slavery Act 2015, as our turnover is below the £36 million threshold. We publish this statement voluntarily because our customers, including UK healthcare groups, rightly expect transparency from their suppliers, and because we support the aims of the Act.

1. Our structure, business and supply chains

Alto develops and supplies a software platform that processes clinical referrals for hospitals and healthcare providers. The platform is delivered as cloud software (SaaS); we do not manufacture, ship or store physical goods.

  • Alto Health Limited is the operating company, registered in Ireland. It employs our staff, holds customer and supplier contracts and carries out our commercial activity.

  • Alto Health UK Ltd, registered in Northern Ireland, is the legal manufacturer of our software medical device.

  • We are a small team of employees and contractors, based in Ireland and the UK.

  • Our main suppliers are: cloud hosting and software service providers (including productivity, communication, CRM and AI services); professional services (accountants, solicitors, consultants and clinical advisers); and office and co-working providers in Dublin and Belfast.

2. Our policies

  • Anti-Bribery and Anti-Corruption Policy

  • Sanctions Compliance Policy

  • Supplier Compliance Declaration, which our key suppliers are asked to confirm

  • Speak-Up (Whistleblowing) Policy

All workers are recruited directly or engaged under written contracts, are paid at or above the applicable minimum wage, and are free to leave their employment on notice. We do not use recruitment agencies that charge fees to workers.

3. Due diligence

Before engaging a new supplier that is material to our business, we review who they are, where they operate and what they will do for us. For our largest and most important suppliers, we ask them to confirm our Supplier Compliance Declaration or to provide their own modern slavery statement. We favour established suppliers who publish their own statements or equivalent human rights commitments.

4. Risk assessment and management

We consider our direct risk of modern slavery to be low: our workforce is small, skilled and directly engaged, and we do not buy physical goods in volume. The areas where risk is higher are:

  • Hardware and electronics used by the global technology services we rely on, where supply chains are complex and extend to higher-risk countries;

  • Outsourced or offshore technical services, such as freelance development or data-labelling work;

  • Facilities services such as cleaning and security at shared offices, which are provided by our landlords.

We manage these risks by using reputable, established suppliers, asking key suppliers for assurances, and reviewing any concerns raised with us.

5. Effectiveness

We will track the following each year:

  • Percentage of key suppliers that have provided a modern slavery statement or signed our declaration (target: 100%);

  • Number of concerns raised and how they were resolved;

  • Completion of awareness training by staff.

6. Training

All employees receive a short briefing on modern slavery, how to recognise warning signs and how to raise a concern within 10 days of joining, and again when this statement is updated. All current employees have completed it. Directors and anyone responsible for procurement receive the briefing annually.

Raising concerns

Anyone who has a concern about modern slavery connected with our business can raise it with Peter Donnelly (peter@altohealth.io) or through our Speak-Up Policy. Concerns can be raised in confidence and will be investigated promptly.


Approved by the board of directors of each company on 1 October 2026.

Signed by Marita Kenrick, Director, for and on behalf of Alto Health Limited and Alto Health UK Ltd, 1 October 2026

Version 1.0 | Owner: Directors | Approved 1 October 2026 | Next review: October 2027