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Modern Slavery Statement

Version: 1.1
Dated: 1 February 2025

1. Policy statement

SpotDev Services Ltd ("SpotDev") has zero tolerance for modern slavery, human trafficking, forced labour, or servitude in any part of our business or supply chain. We commit to acting ethically and with integrity in all dealings and to implementing effective systems and controls to safeguard against such practices.

2. Purpose

This document sets out how SpotDev fulfils its obligations under the Modern Slavery Act 2015 and related international standards. It applies to all employees, officers, contractors, agency workers, consultants, and suppliers.

3. Responsibilities

Role Key duties
Chief Executive Day‑to‑day leadership; ensures adequate resources. Overall accountability; annual approval of this policy and any public statement.
Director of Operations Maintains risk register; oversees supplier due‑diligence programme.
All employees and contractors Read, understand and comply; report concerns.

4. Our organisation & supply chains

SpotDev is a UK‑registered technical consultancy. We have two delivery teams (Technical Delivery and Design & Development) and a remote workforce in the United Kingdom, European Union and South Africa. Our supply chain is service‑heavy (software licences, professional services, and IT hardware). We classify suppliers as Tier 1 (direct) and Tier 2 (critical sub‑contractors).

5. Policies & procedures

  • Employee Code of Conduct
  • Supplier Code of Conduct 
  • Recruitment & Right‑to‑Work Procedure
  • Grievance & Whistle‑blowing Policy
  • Anti‑Bribery & Corruption Policy

6. Due‑diligence processes

  1. On‑boarding: All Tier 1 suppliers will have their modern slavery policies reviewed.
  2. Contractual controls: Standard terms include a modern‑slavery clause and audit rights.
  3. Screening: Open‑source checks for adverse media, sanctions, and convictions.
  4. Audit: High‑risk suppliers may be subject to a desktop or on‑site audit.

7. Risk assessment & management

Risk area Rationale Mitigation Residual risk
Third‑party SaaS providers Low direct labour risk but potential subcontracted data‑centre staff. ISO 27001/SOC 2 disclosures. Low

8. Key performance indicators

Indicator Target FY 2025/26
% Tier 1 suppliers where policies have been reviewed 100 %
Modern‑slavery policy review 100% within 30 days of onboarding
Reported incidents 0 substantiated cases

9. Training

All new employees review our modern slavery policy; refresher reviews are completed every two years. Managers with procurement authority receive enhanced training on supplier due diligence.

10. Reporting concerns

Employees or external parties may report suspected modern‑slavery issues via:

No reprisal will occur for genuine reports.

11. Monitoring & review

The Director of Operations will monitor implementation and report quarterly to the board. The policy will be reviewed at least annually, or sooner if legislative or organisational changes require.