Willow Innovations, Inc., trading as “Willow”, is committed to doing business in compliance with applicable laws, in an ethical, transparent, and sustainable way, and according to our core values.

Opening statement

“As a femtech company, we are committed to supporting women in balancing motherhood and womanhood with products that genuinely make a difference. Respect, care, and fairness are at the heart of this work, and every part of our business and the partnerships we engage in reflects these values. That includes actively championing an ethical and transparent supply chain. 

We are vehemently against modern slavery and human trafficking in all its forms, and there's no room in our business or supply chain for any exploitation. We take this responsibility seriously and only work with partners who share our values, because building trust with you—and with everyone who helps bring our products to life—matters deeply to us. 

Our dedication to innovation in women's health and wellbeing is unwavering, and caring for women means caring for people everywhere.” 

Janet Yeh, VP Operations 

Elvie’s processes and ways of doing business focuses on both ethical, legal and regulatory compliance across its business including development, production, sales and product after-case support. In accordance with the UN Global Compact and the OECD Guidelines for Multinational Enterprises, Elvie integrates sustainability and corporate responsibility into its business.

Elvie strives to conduct business with individuals and organizations that do business in the same manner. To support our suppliers in meeting these expectations – and to ensure transparency and declare our efforts in identifying, assessing and managing the risks of modern slavery and human trafficking within our supply chain pursuant to the Modern Slavery Act 2015.

As part of our commitment to combating modern slavery and human trafficking, we have implemented the following policies:

1. Our suppliers shall adhere to applicable employment law and environmental protection, health and safety legislation and provides general guidelines for our day-to-day supply chain business.
2. Elvie supports and respect the internationally recognized Human Rights as stated in the United Nations Global Compact. Our Suppliers are expected to also uphold these rights and to treat their employees accordingly. We do not accept any violations of these rights and will intervene in the case of adverse events.
3. Our Suppliers shall respect their employees' and subcontractors' fundamental rights at work.
4. We do not accept forced labor or exploitation. Our Suppliers may not use forced, bounded or indentured labor or pay unreasonable remuneration. Working hours of their employees and subcontractors shall not exceed limitations set in applicable laws and be reasonable.
5. Workers should be free to leave the company upon reasonable notice, at least as provided by applicable law. They shall not be obliged to surrender identification documents, passports or work permits as a condition of employment or subcontracting.
6. Minors under the minimum employment age of 15 (14 in countries with less developed educational systems) years according to Sec. 2.4 of the International Labour Organisation Convention Nr.138 may not be hired.

Due Diligence  

Elvie operates a supplier on-boarding risk assessment process. As part of the due diligence process, our suppliers complete a compliance self-assessment questionnaire via the SEDEX platform covering both local law and international regulatory compliance. We will also ask if suppliers have alternative credentials supporting good ethical practices such as BSCI certification.  Depending on various risk factors, on-boarding due diligence may consist of a desktop audit of the supplier’s SEDEX profile and listed documentation and, in higher risk cases, even an on-site audit. Our supplier contractual obligations also include compliance with laws and adherence to our Supplier Code of Conduct which specifically calls out compliance with ethical procurement issues such as modern slavery, human trafficking, labour standards and worker welfare throughout supply chains. This due diligence procedure is designed to:

1. establish and assess areas of potential risk in our business and supply chains;
2. monitor potential risk areas in our business and supply chains;
3. reduce the risk of slavery and human trafficking occurring in our business and supply chains; and
4. provide adequate protection for whistleblowers.

Risk management

Elvie regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by ensuring that it only appoints suppliers who pass the due diligence process and in whom we have confidence adhere to property labour standards. Our assessment will weigh several factors such as:

1. country risks - exposure may be greater in global supply chains involving countries where protection against breaches of human rights are more limited; and 
2. sector risks -  mass manufacture of goods is known to be a higher risk industry, particularly in the electronic goods sector.

We therefore consider that we operate in a moderate risk sector and locations because we outsource our manufacturing to third parties in China and Thailand. 

Where we have identified a potential risk, we take great care to conduct on-side audits of such supply partners to give ourselves as much confidence as possible that there are no modern slavery practices in effect. This is in addition to our standard on-boarding due diligence and continued collaboration and partnership investment throughout our working relationship.

We ensure all our suppliers adhere to our Supplier Code of Conduct which specifically calls out compliance with ethical procurement issues such as modern slavery, human trafficking, labour standards and worker welfare throughout supply chains. We require a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains.

Effectiveness and KPIs

Elvie uses key performance indicators (KPIs) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains. These are as follows:

• Adherence to our Supplier Code of Conduct by all manufacturing partners
• Training to all product and operational teams about the risks and warning signs regarding slavery and human trafficking
• Carrying out at least 3 supplier audits each year
• Regular benchmarking of its approach to managing the risk of modern slavery

Training

We educate our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy.

Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

Further actions and sign-off

Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking:

• Unify the Willow Group supplier on-boarding process across the Willow and Elvie products 
• Improve control such documentation by incorporating this into the Willow Group e-Quality Management System
• Roll out across the Willow Group compliance training on Modern Slavery to ensure the messaging is consistent and better documented

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Willow/Elvie’s slavery and human trafficking statement for the period up to 30 September 2025.

This statement was approved by the Board of WIllow Blossom HoldCo Limited, the Willow Group UK entity, on October 14th, 2025.