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Introduction

Modern slavery is a grave violation of human rights and a morally indefensible practice that strips individuals of their liberty and dignity for the benefit of others. It remains a pervasive issue, affecting millions globally—including within developed nations—where individuals continue to be exploited through forced labour, human trafficking, and other forms of servitude.

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At OpusDatum, we uphold a zero-tolerance approach to modern slavery in all its forms. We are fully committed to preventing slavery and human trafficking across both our operations and supply chain. This statement outlines the steps we have taken to understand the risks of modern slavery in our business and the measures implemented to mitigate and prevent such practices.

 

Our Business & Supply Chain

Our business ethos is grounded in building strong, transparent, and ethical relationships with subcontractors and suppliers. These partnerships are based on mutual trust and shared commitments to lawful and responsible conduct. As part of our subcontractor and supplier selection and onboarding process, we undertake thorough due diligence. This includes assessments of legal compliance, reputation, adherence to health, safety and environmental standards, and the collection of appropriate references.

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We have not received any reports or allegations of modern slavery or human trafficking linked to any of our suppliers. Nonetheless, we remain alert to such risks and have put in place clear protocols to ensure we can respond swiftly and appropriately. Should any concerns arise, we would take immediate action, including reporting to the relevant authorities and taking steps to terminate business relationships where necessary.

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Risk Assessment

During the past year, we conducted a structured risk assessment to identify potential modern slavery risks across our supply chain. This assessment considered the country-specific risks using the Global Slavery Index, the types of services provided by our suppliers, and the potential exposure of vulnerable demographic groups. It also incorporated reviews of public domain information, including news articles and insights from human rights and labour organisations.

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These findings inform our tailored response strategy, ensuring that risk controls are proportionate and effective. Where higher risks are identified, we escalate our due diligence and monitoring accordingly to mitigate exposure and strengthen oversight.

 

Policies

OpusDatum Ltd operates a suite of internal policies to reinforce our commitment to identifying and preventing modern slavery and human trafficking within our operations. Our Whistleblowing Policy plays a key role by encouraging all employees, subcontractors, clients, and suppliers to report concerns confidentially and without fear of retaliation. We provide access to a secure and anonymous helpline to support whistle-blowers and promote transparency.

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Our Code of Conduct defines the behaviours and ethical standards expected of all employees and subcontractors when representing the business. It outlines our values and reinforces our commitment to integrity, especially when working in international contexts or engaging with third-party partners. Additionally, our Purchasing Code has been updated to include explicit references to modern slavery and human trafficking, and these expectations are embedded within our supplier contracts.

 

Supplier Due Diligence

We conduct due diligence on all new suppliers during the onboarding process and continue to monitor existing suppliers on a regular basis. This includes evaluating the level of risk associated with the specific services provided, reviewing employment conditions, labour relations, and health and safety practices, and identifying any areas for improvement. Where employment practices fall short of our standards, we work with the supplier to achieve compliance and reserve the right to apply sanctions for non-compliance.

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We require all subcontractors and suppliers to confirm that they do not engage in any form of forced, bonded, or involuntary labour. Employees must work freely and have the right to terminate their employment with reasonable notice. All staff must be provided with legally compliant employment contracts. Suppliers must not require employees to pay deposits or surrender identification documents as a condition of employment, nor may they withhold wages unlawfully or restrict an individual’s right to leave.

 

Awareness

To raise awareness of modern slavery, we have undertaken an internal campaign involving visual messaging across our facilities and direct communication with staff. This includes an all-staff email outlining the nature of modern slavery, the Company’s stance against it, and guidance on recognising warning signs and reporting concerns. These communications are designed to reinforce our values and enhance our collective vigilance.

 

Training

Alongside our awareness initiatives, we have delivered a structured training programme for all employees and subcontractors. This training explores the various forms of modern slavery, the scale of the issue globally and in the UK, and the specific risks faced by organisations like ours. It equips participants with the knowledge to identify red flags—such as unrealistically low contract prices—and provides step-by-step guidance on how to respond to and report any suspicions.

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The training also offers advice for suppliers on how to escalate concerns internally and externally, outlines support services available to victims, and details our expectations regarding the implementation of anti-slavery measures. Employees and subcontractors are required to formally attest to their understanding of and compliance with our anti-slavery commitments.

 

Performance Measurement

To evaluate the effectiveness of our approach, we have introduced key performance indicators and controls. These include tracking the completion rate of our mandatory training programme, monitoring the proportion of suppliers completing our ethics questionnaire, and assessing whether suppliers have adopted awareness and training measures equivalent to our own. We also review the number and nature of internal reports related to ethical concerns to assess staff engagement and awareness.

 

Remediation Process

Our response framework includes a structured remediation process to ensure that any suspected instances of modern slavery are addressed comprehensively and with sensitivity. We have established confidential and accessible grievance mechanisms, which allow individuals to raise concerns safely and anonymously. These mechanisms also serve as an early warning system, helping to identify and address issues at an early stage.

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Where potential victims are identified, our approach prioritises safety, protection, and dignity. We involve affected individuals in shaping remediation plans and ensure their privacy is maintained. The Company collaborates with relevant authorities, legal advisors, and specialist organisations, and where appropriate, engages mediators or negotiators. All significant incidents are escalated to the Board for oversight and direction.

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We follow a human rights-based, victim-centred approach, seeking to restore affected individuals to their pre-incident condition wherever possible. Remedial support may include access to legal services, medical care, counselling, and safe temporary accommodation. In some cases, financial remedies may be offered, such as the repayment of withheld wages or covering travel and repatriation costs. We may also take further steps, such as issuing formal apologies or amending our practices to prevent recurrence.

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This statement has been prepared in accordance with Section 54 of the Modern Slavery Act 2015 and reflects the actions taken by OpusDatum Ltd during the financial year ending 31 March 2025. It has been approved by the Board of Directors and will be reviewed annually.