Governance & Compliance Statement

Our Governance Approach

Wellbeing Places Equip Limited ("WBP Equip") operates as a technology and product company committed to high standards of governance, accountability, and responsible innovation.

The Company's governance framework is designed to ensure that:

• decision-making is clear, accountable, and appropriately documented;
• risks associated with technology, data, and AI are identified and managed;
• legal and regulatory obligations are met; and
• stakeholders, including investors and partners, can place confidence in the way the business is directed and controlled.

Governance arrangements are proportionate to the scale and maturity of the business and are reviewed regularly as the Company evolves.

Board Oversight and Accountability

Overall responsibility for governance, risk, and compliance rests with the Board of Directors.

The Board is responsible for:

• setting the Company's strategic direction and risk appetite;
• approving key governance and compliance policies;
• overseeing risk management and escalation arrangements; and
• ensuring appropriate internal controls are in place.

Day-to-day responsibilities may be delegated to management or advisers, but accountability remains with the Board.

Risk Management and Control

WBP Equip maintains structured processes to identify, assess, and manage risks across its operations.

Key areas of focus include:

• technology and AI-related risk;
• data protection and privacy;
• information security;
• legal and regulatory compliance;
• supplier and third-party risk; and
• ethical and reputational considerations.

Risks are monitored on an ongoing basis, with material issues escalated for senior review and action.

Responsible Use of Technology and AI

WBP Equip is committed to the responsible development and use of technology, including artificial intelligence.

The Company's approach is based on the following principles:

• Human oversight: automated systems are not relied upon in isolation for critical outcomes.
• Transparency: the use and limitations of technology are considered in design and deployment.
• Fairness and integrity: reasonable steps are taken to identify and mitigate bias or unintended impacts.
• Accountability: responsibility for outcomes remains with the Company, not with automated tools.

Independent expert input may be sought to support validation, assurance, or review where appropriate.

Data Protection and Information Governance

The Company recognises the importance of protecting personal and sensitive data.

WBP Equip maintains policies and procedures designed to ensure that:

• data are processed lawfully, fairly, and transparently;
• appropriate safeguards are applied to protect confidentiality and integrity;
• data are retained only for as long as necessary; and
• incidents or concerns are addressed promptly and responsibly.

Further information on how personal data are handled is set out in the Company's Privacy Notice.

Information Security

WBP Equip applies proportionate information-security controls to protect its systems, data, and digital assets.

These controls include measures relating to:

• access management;
• secure system design and operation;
• monitoring and incident response; and
• oversight of third-party suppliers where relevant.

Security arrangements are reviewed periodically to reflect changes in risk and business activity.

Independent Assurance and Advisory Support

Where appropriate, the Company may engage independent third-party experts to provide professional advice, validation, or assurance in relation to technology, data, or governance matters.

Such engagements are intended to strengthen decision-making and risk management while preserving clear accountability within the Company.

Transparency and Review

This Governance & Compliance Statement reflects the Company's current approach and is reviewed periodically.

The Company may update this statement as its operations, risk profile, or regulatory environment change.

This policy is reviewed:

• annually; or
• earlier if there is a material change in law, regulation, business model, or risk profile.

All revisions must be approved by the Board and recorded in the Policy Register.