Code of Conduct

This Code of Conduct sets out the standards of behaviour expected of everyone who works at or with Klarity Health (“Klarity”), including employees, contractors, consultants and directors. It reflects our commitment to operating with integrity, respect and transparency.

Klarity’s mission — using predictive analytics to improve morbidity and mortality outcomes — depends on the trust of patients, clinicians, health systems and partners. This Code helps protect that trust.

Everything we do is guided by four core values:

• Integrity – we are honest, transparent and accountable in all we do.

• Respect – we treat every person with dignity, fairness and empathy.

• Excellence – we hold ourselves to high professional and scientific standards.

• Purpose – we stay focused on outcomes that genuinely improve patient lives.

Klarity is committed to a workplace free from discrimination, harassment and bullying. We do not tolerate unfair treatment on the basis of age, gender, race, ethnicity, religion, disability, sexual orientation, pregnancy, or any other protected characteristic.

Everyone at Klarity is expected to:

• Treat colleagues, clients and partners with courtesy and respect.

• Speak up if they witness or experience inappropriate behaviour.

• Engage constructively with differences of opinion.

A conflict of interest arises when personal interests could — or could appear to — interfere with acting in Klarity’s best interests. Common examples include holding financial interests in a competitor or supplier, or conducting outside work that competes with Klarity.

If you believe you may have a conflict of interest, you must disclose it promptly to your line manager or a director. Disclosure allows the situation to be managed; concealment is a serious breach of this Code.

We handle sensitive health data and commercially confidential information. You must:

• Comply with all applicable data protection legislation, including the UK GDPR and the Data Protection Act 2018.

• Not share confidential information about Klarity, its clients or its data with unauthorised parties.

• Follow Klarity’s data security policies and report any suspected breach immediately.

These obligations continue after employment ends.

Modest, infrequent gifts or hospitality may be acceptable when they are not intended to influence a business decision. As a general guide, any gift or hospitality with a value above £50 should be declared to your line manager. You must never offer or accept anything that could be perceived as a bribe. See also the Anti-Bribery and Corruption Policy.

Company equipment, systems, funds and time must be used responsibly and primarily for legitimate business purposes. Incidental personal use is acceptable where it does not interfere with your duties, create a cost or reputational risk, or breach any other policy.

When posting publicly online, be mindful that you may be identified as a Klarity employee. You must not share confidential information, make misleading statements about Klarity or its products, or post content that is discriminatory or defamatory. If in doubt, seek approval before posting about Klarity.

Everyone at Klarity is expected to comply with all applicable laws and regulations in the jurisdictions in which we operate. This includes, but is not limited to, competition law, financial regulation, healthcare regulation and health and safety legislation.

If you become aware of a potential breach of this Code or any applicable law, you should report it. You can speak to your line manager, a director, or use the confidential reporting mechanism described in the Whistleblower Policy.

Klarity does not tolerate retaliation against anyone who raises a genuine concern in good faith.

Breaches of this Code may result in disciplinary action up to and including dismissal, and may in some cases be referred to relevant regulatory or law enforcement authorities.

This Code is reviewed annually by the Klarity leadership team. Questions about its application should be directed to a company director.

Approved by Klarity Health leadership · March 2026