Modern Slavery

Modern Slavery and Human Trafficking Policy Statement

This statement sets out Platformation Enterprise Services Ltd’s commitment to preventing modern slavery and human trafficking in our organisation, its business and its supply chains, and the steps we take to identify, manage and monitor risks, in line with the spirit of the Modern Slavery Act 2015.

Our policies in relation to slavery and human trafficking

  • We are committed to combating all forms of slavery and human trafficking in our organisation and across our supply chains.
  • Our policies include a Modern Slavery/Anti-Slavery Policy, a Supplier Code of Conduct (covering employment standards, recruitment practices, wages, hours, health and safety, freedom of movement, and the right to freely choose employment), and clear whistleblowing arrangements.
  • We will prohibit the use of forced labour, child labour, bonded labour, servitude, or human trafficking in any part of our business or supply chain, and we will terminate relationships with suppliers who fail to meet our standards or who obstruct remediation.
  • We expect our suppliers and partners to comply with applicable laws and to adopt equivalent anti-slavery measures within their own operations and supply chains.

Our due diligence processes in relation to slavery and human trafficking in our business and supply chains

  • We conduct ongoing due diligence to identify and assess potential AS/HT risks within our operations and across our supply chains.
  • Our due diligence includes: a risk-based supplier onboarding process, regular supplier assessments, consideration of high-risk categories and geographies, and the requirement that suppliers acknowledge and adhere to our Supplier Code of Conduct.
  • We require suppliers to provide evidence of compliance or to engage with us on corrective action plans. Where necessary, we conduct or commission audits or third-party verifications to validate compliance.
  • We maintain a process for raising concerns through our confidential reporting channels and for implementing remediation where issues are identified.

The parts of our business and supply chains where there is a risk of slavery and human trafficking and the steps taken to assess and manage that risk

  • While we do not consider modern slavery to be a significant risk within our operations and supply chains, we recognise that risks exist and must be monitored and mitigated.
  • Risk assessment and management measures include:
    • Mapping of high-risk supplier relationships (e.g., recruitment agencies, migrant labour suppliers, and subcontractors).
    • Routine due diligence on supplier governance, labour standards, wages, working hours, and recruitment practices.
    • Required implementation and monitoring of our Supplier Code of Conduct, with audits or third-party verification where appropriate.
    • Clear escalation paths and remedial action plans for any issues identified, including supplier development or disengagement if corrective actions are not feasible or timely.
    • Regular review of risk indicators and changes in operations that could alter risk profiles.
  • We continuously monitor and reassess risks to ensure that any emergence of slavery or trafficking is detected and addressed promptly.

Our effectiveness in ensuring that slavery and human trafficking is not taking place in our business or supply chains, measured against such performance indicators as we consider appropriate

  • We measure effectiveness through a set of indicators, including:
    • Completion rates of supplier due diligence and acknowledgement of the Supplier Code of Conduct.
    • Incidents or concerns raised through confidential reporting channels and the outcomes of investigations.
    • Remediation actions completed and time to remediate identified issues.
    • Training completion rates and staff engagement with AS/HT awareness programmes.
    • Geographical or categorical risk re-assessment results indicating changes in risk levels.
  • We use these metrics to inform policy updates, supplier development plans and decisions to engage or disengage with suppliers. The policy is reviewed annually and updated in light of the measured effectiveness.

Training and capacity building about slavery and human trafficking available to our staff

  • We provide training and awareness programmes for employees across the organisation, with a focus on procurement, operations, finance and management involved in supplier relationships.
  • Training covers: definitions and indicators of modern slavery, relevant laws and company policies, due diligence processes, how to identify red flags, how to report concerns and how remediation works in practice.
  • Training delivery methods include e-learning modules, instructor-led sessions, and targeted workshops. All relevant staff are required to complete training on a periodic basis (e.g., annually or more frequently where required by role or risk profile).
  • We maintain capacity-building initiatives, including supplier-facing guidance and, where appropriate, collaborative improvement projects with key suppliers to strengthen labour standards and recruitment practices.

Governance, accountability and publication

  • Our governance framework assigns clear responsibility for anti-slavery and human trafficking (AS/HT) matters to the Board under the leadership of the Chief Executive Officer.
  • The policy is reviewed and refreshed annually, or sooner if risk profiles change, and is approved by the Chief Executive Officer.
  • We publish this statement on our website and provide it to stakeholders as part of our commitment to transparency. A summary version suitable for public dissemination will be maintained and updated alongside the full policy.