Spire Healthcare Group plc

The purpose of this Board Diversity Policy (the Policy) is to set out the approach to diversity for the board of directors of the Company (the Board) and for its Committees¹ . It is intended to assist the Board (through the Board succession planning work of the Nomination Committee) in creating and maintaining the appropriate Board and Committee composition.

Spire Healthcare understands and values the benefits that diversity can bring to its Board, and across all levels of the organisation. A diverse Board includes and makes good use of a diverse mix of skills, experience, background, independence of thought, ethnicity, gender, age, and broader aspects of diversity which may include, for instance, disability, sexual orientation and socio-economic background. These features collectively represented on the Board ought to reflect the diverse nature of the environment in which the Company operates. The aim is to ensure optimal decision-making that assists in the development and execution of a strategy which promotes the long-term sustainable success of the Company generating value for shareholders and other stakeholders, as well as contributing to wider society.

The Company will seek to maintain a minimum of 40% female representation on the Board, have at least one senior position on the Board to be held by a woman, and have at least one individual on the Board from a minority ethnic background. The Company is committed to meet the targets of the Parker and FTSE Women Leaders Reviews and the Financial Conduct Authority’s Listing Rules as far as possible, recognising that there may be temporary periods when this is not possible; such periods should be minimised.

Whilst making new appointments to the Board on merit, the Board will actively seek to secure candidates with a diverse background. Appointments will take account of the specific skills and experience, resilience, independence and knowledge needed to ensure a rounded Board and the diverse benefits each candidate can bring to the overall Board composition. The Board will promote diversity and inclusivity within the organisation, including supporting women to become leaders within the business and improving the diversity of the Company’s workforce.

Through its Annual Report and Accounts, the Nomination Committee will report on the process in relation to Board appointments. The report will also include the application of this Policy, confirmation of the measurable objectives and progress made towards achieving them, the approach to succession planning, actions to develop a diverse pipeline of candidates, how diversity helps the Company meet its strategic objectives, and the gender balance of senior managers and their direct reports.

The Nominations Committee will review the Policy, including its effectiveness, annually and recommend any revisions to the Board for approval. A copy of this Policy will be made available on the Company’s website.

Adopted by the Board of the Company on 29 July 2025

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¹ For the purposes of this Policy, “Committees” means the Audit and Risk Committee, the Remuneration Committee and the Nomination Committee of the Board.