UK Modern Slavery Statement for 2025
This United Kingdom Modern Slavery Statement has been prepared pursuant to the UK Modern Slavery Act (2015). It sets out the steps that Heartflow has taken to address modern slavery in our business and supply chains.
About Heartflow
Heartflow has pioneered the use of software and AI to deliver a more accurate and clinically effective noninvasive solution for diagnosing and managing coronary artery disease (“CAD”), a leading cause of death worldwide. As of December 31, 2024, our Heartflow Platform has been used to assess CAD in more than 400,000 patients. We believe that we are the most widely adopted AI-powered test for CAD. Our novel platform leverages AI and advanced computational fluid dynamics to create a personalized 3D model of a patient’s heart from a single coronary computed tomography angiography (“CCTA”), a specialized type of scan that provides detai led images of the heart’s arteries.
Our Heartflow Platform delivers actionable insights on blood flow, stenosis, plaque volume and plaque composition thereby overcoming the limitations of traditional non-invasive imaging tests which rely on indirect measures of coronary disease and lead to higher false negative and false positive rates, as demonstrated by our PRECISE trial. We believe the differentiated accuracy and clinical utility of our Heartflow Platform, along with its ability to enhance workflows, will continue to support our growth and advance the “CCTA + Heartflow” pathway as the definitive standard for the non-invasive diagnosis and management of CAD.
As of December 31, 2024, we had approximately 700 employees worldwide, the majority of whom are located in the United States, with 12 employees located in the United Kingdom, all of whom are skilled sales and support service professionals.
Heartflow operates production facilities in the United States. Heartflow does not have manufacturing facilities, and does not have any production facilities in the UK. Heartflow’s product is delivered digitally to customers and as such, there are no materials or components in the design, development, and manufacture of our products.
Heartflow has engaged with or considered engaging with approximately 200 suppliers or vendors globally. A very limited number of these suppliers are located in the UK or do business with Heartflow in the UK.
Risk of Modern Slavery in Our Operations
We consider the risk of modern slavery in our UK operations to be low given our internal policies and procedures, commitment to strong governance, and the professional nature of our workforce. Our employees are expected to adhere to our code of conduct, principles governing our business, and commitment to integrity and high ethical practices. Our policies apply globally to all of our employees, members of the Board of Directors, and agents of Heartflow. The principles governing our business include, among other, fair employment and safe work environment practices, compliance with local laws and regulations, and commitment to being productive and respectful members of the communities where we do business. Pursuant to our employment policies and procedures, we strive to hi re only employees that are authorized to work in accordance with applicable employment laws in the country in which they are located and have processes in place to mitigate risks of noncompliance. Additionally, regular full-time employees at Heartflow must be at least 18 years of age.
Risk of Modern Slavery in Supply Chain
We believe the risk of modern slavery occurring at Heartflow’s UK direct suppliers in connection with providing goods and services to Heartflow to be relatively low due to nature of our operations in the UK, the policies and procedures we have in place to reduce or mitigate those risks, and the strength of our relationship with our suppliers. We have policies applicable to suppliers and third parties with whom we do business. In addition, we conduct regular desktop audits of our suppliers for their risk level, and include in this audit factors set forth in the global slavery index and the US Department of Labor. Our most recent audit was in 2024, and no suppliers were identified as medium or high risk.
Section 54 of the UK Modern Slavery Act (2015) requires commercial organisations that operate in the UK and have an annual turnover above £36m to produce a Slavery and Human Trafficking statement each year.
We do not have an annual turnover above £36m, so therefore are not required under this legislation to produce a yearly statement. However, we choose to voluntarily produce a statement.
Our Supply Chain and Procurement – Actions Taken to Assess and Address the Risk of Modern Slavery
Heartflow is committed to ensuring transparency in our own business and our supply chains and expect the same due diligence and commitment from our suppliers, contractors and business partners. When procuring goods or services we have processes in place to carry out third party due diligence, which includes:
- Supplier selection process and policies – all suppliers are submitted to the Procurement Committee for evaluation and approval following completion of a supplier evaluation request form.
- Supplier questionnaire, audit and periodic reviews by the Procurement Committee in accordance with our supplier management procedures.
- Regular assessments of the supply chain to identify geographical or operational areas of higher risk.
We continue to enhance and evolve our process for engaging with third parties, including implementing the following actions in the near term:
- Requiring high risk suppliers, as part of the contract, to adhere to modern slavery policies and principles.
- Requiring our suppliers, as part of the selection process and yearly auditing, to confirm adherence to our supplier code of ethics.
- Auditing of our suppliers, focusing on those that are the higher risk.
Employee-Related Policies and Training
All Heartflow employees are required to comply with our code of conduct, and our employees participate in periodic training to enhance understanding and compliance with the code. In addition, we audit employee compliance with the our policies, investigate potential violations and, when appropriate, take corrective or disciplinary action.
Raising Concerns
Employees are encouraged to speak up and report concerns through a variety of methods, including our ethics hotline.
Responsibility
Heartflow staff with responsibility for this statement:
Chief Legal and Compliance Officer
Chief Human Resource Officer
Senior VP, International Sales, Marketing, and Customer Success
VP, Finance/Procurement
Assessment
In addition to our supplier engagement process, we devote resources to assess and improve on our processes, including the process of monitoring and evaluating our existing suppliers. We carefully review audit assessment results and any submissions made through our grievance mechanism and dili gently address any issues raised. Furthermore, we regularly measure the effectiveness of our actions using key performance indicators including tracking the number of modern slavery cases identified and remediated, annually reviewing this Statement, and continuing to evolve our supplier / procurement program. We strive to reduce the risk associated with modern slavery, enhance awareness of such risks in our supply chains, and engage with stakeholders on compliance with applicable law and our policies.
Approval
This Statement was approved by the board of directors of HeartFlow U.K. Ltd. and signed by Vikram Verghese, a director of Heartflow U.K. Ltd. on June 26, 2025.
