Modern Slavery Statement

Version: 1.3
Effective date: 6 Sep 2026
Next review: 6 Sep 2027
Owner: COO

1. Commitment and purpose

SpotDev Services Ltd has zero tolerance for slavery, human trafficking, forced labour and servitude in our business or supply chain. We require ethical conduct and take concerns seriously.

We publish this statement voluntarily to explain our approach to clients, suppliers, personnel and other interested parties. It applies to our business relationships and people acting on our behalf.

2. Our business and supply chain

We are a UK software engineering and implementation business serving clients through a remote workforce. Our supply chain includes software and cloud services, professional services, contractors and IT equipment. Our working arrangements include the United Kingdom, the European Economic Area and South Africa.

A service-based business can still be exposed through recruitment practices, subcontracting, equipment manufacture and labour used by suppliers. We do not treat geography, supplier size or security certification as proof that exploitation risk is absent.

3. Governance and expected conduct

The Board oversees this commitment. The Chief Executive retains executive accountability and the COO coordinates implementation, supplier assessment and reporting. Managers and personnel must raise concerns and follow relevant contractual and conduct requirements.

We prohibit coercive recruitment, forced labour and restrictions on a person's freedom to leave work. Recruitment and engagement arrangements must be lawful and understandable. Supplier and contractor terms should communicate appropriate ethical standards, reporting expectations and remedies for non-compliance.

4. Due diligence and risk assessment

Supplier assessment must consider the service, country, workforce arrangements, subcontracting and credible adverse information. Direct suppliers are expected to be reviewed at onboarding for relevant modern-slavery information. Higher-risk relationships require additional enquiries, evidence or contractual safeguards, and may require further review or audit where appropriate and available.

Security certifications may support security assurance, but they do not replace labour-practice or human-rights due diligence. Concerns should be recorded, assessed and assigned an owner. Responses may include seeking information, requiring corrective action, restricting new work or ending a relationship where appropriate, while considering the effect on potentially affected people.

5. Awareness and reporting

New employees are required to review this policy, with refresher reviews every two years. Personnel with procurement responsibility require awareness appropriate to supplier risk. Training and acknowledgements must be recorded.

Personnel and external parties can raise concerns through hello@spotdev.co.uk, requesting the COO or Chief Executive. Reports are handled sensitively. Retaliation against a person raising a genuine concern is prohibited. Where there is immediate danger, contact the appropriate emergency services.

6. Monitoring and improvement

The COO is responsible for monitoring implementation and reporting quarterly to the Board. Our targets include review of all direct suppliers' relevant modern-slavery information and policy acknowledgement within 30 days of onboarding. These are targets, not statements that coverage has already been achieved.

Reporting should distinguish completed reviews from the total relevant population, identify overdue actions and track how concerns are assessed and addressed. We encourage reporting; a low number of reports is not, by itself, evidence of effective controls.

We review this statement annually and after material changes. The COO maintains records of assessments, training and resulting actions.