Sword Health Modern Slavery Statement
1. Introduction
Sword Health (“Sword”, “we”, “our”) is committed to operating ethically and with integrity, and to putting in place systems to ensure that slavery and human trafficking are not taking place in our business. This statement sets out the steps we have taken during the most recent fiscal year to prevent modern slavery and human trafficking in accordance with our obligations under applicable law and our own values.
2. Organisational structure, business, and supply chains
● Organisational structure and business model: Sword Health is an AI health company specializing in AI-powered physical therapy for musculoskeletal (MSK) conditions, pelvic health, injury prevention, and pain management.
● Geographic presence: We operate internationally, with registered offices in the U.S., Portugal, and the United Kingdom, among other locations.
● Supply chains:
○ We procure technology hardware (e.g., motion sensors, tablets) to support our digital therapy platform.
○ We rely on third-party software providers, cloud infrastructure, and professional services.
○ We contract with clinical professionals (therapists, physiotherapists) in various geographies.
○ We engage with logistics providers (for distributing devices to patients) and office services for our operations.
3. Policies on slavery and human trafficking
● We support a zero-tolerance policy toward slavery, servitude, forced labour, and human trafficking in any part of our business.
● Our internal policies and procedures set clear expectations for ethical behaviour, including respect for human rights.
● We are standardizing our procurement process to require suppliers adhere to acceptable labour standards, including anti-slavery provisions.
● We provide a whistleblowing mechanism for employees, contractors, and other stakeholders to raise concerns about modern slavery or unethical practices.
4. Due diligence processes
● Supplier assessment: We conduct risk-based due diligence on suppliers, particularly those who are involved in manufacturing hardware, or who operate in higher-risk jurisdictions.
● Ongoing monitoring: We monitor key suppliers through periodic reviews and site visits (if applicable).
5. Risk assessment & management
● Risk identification: We have identified that the highest risk of modern slavery in our operations may lie in:
○ The manufacturing of hardware (motion sensors, wearable devices) which may have multi-tiered supply chains in countries where labour standards are less strictly enforced.
○ Logistics and distribution, particularly for device shipping, where subcontracted labour could pose risk.
○ Office services, such as cleaning or facilities management, which may engage lower-wage workers or subcontracted services.
● Risk mitigation: To manage these risks, we intend to:
○ Prioritize sourcing from reputable hardware manufacturers.
○ Require our logistics partners to provide transparency on their subcontractors.
6. Measuring effectiveness
We assess the effectiveness of our efforts through several performance indicators:
● Incident reporting: Number of reported concerns or whistleblowing incidents related to modern slavery, and actions taken.
● Remediation: Number (or proportion) of identified issues followed by corrective actions, including termination of contracts if needed.
7. Training and capacity building
● We have a code of conduct for, and make this statement available to, suppliers to help them understand our expectations regarding labour rights.
● We encourage an open culture: via our whistleblowing mechanism, any employee or external stakeholder can report suspicions confidentially.
8. Continuous improvement
● We review this statement annually to strengthen our approach and update relevant risk assessments, due diligence, and training processes based on emerging risks, supplier feedback, and performance metrics.
● We support transparency with our stakeholders (employees, investors, customers) about our progress in combating modern slavery.
9. Leadership approval
This statement has been approved by Sword Health’s senior leadership on 19th Jan 2026 and is signed by Matt Beatty (Director, Surgery Hero Limited).
