Modern Slavery Policy

Modern slavery is a violation of an individual’s basic human rights.

Modern slavery is a violation of an individual’s basic human rights. Equal Experts recognises that as a commercial organisation, it has a legal, moral and social responsibility to take a zero-tolerance approach to modern slavery in all forms.

We fully comply with the UK Modern Slavery Act 2015 (“the Act”). We are committed to preventing slavery and human trafficking in our corporate activities and ensuring that our supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

Equal Experts UK Ltd is a management consultancy business engaged in all aspects of software delivery. The company is employed-owned through a trust and limited by shares. It operates in 7 countries with the following wholly owned subsidiaries.

 

 

In relation to Modern Slavery we consider our primary activities to be:

  • Professional consultancy on defining, building and operating software systems
  • Software engineering teams
  • Product and Software Engineering services

We consider our activities to be low risk because our staff and suppliers are very experienced and highly skilled workers.

We consider the countries we operate in to be low risk, except for:

  • South Africa and India (see Risk Section below)

Responsibility

Responsibility for policies and initiatives within the organisation is as follows:

  • Policies are the responsibility of our COO and are reviewed annually.
  • Risk assessments are the responsibility of our Business Unit Lead or the Head of Operations  within each country.
  • Investigations and due diligence for those investigations is the responsibility of our COO, with the appropriate Business Unit Lead or Head of Operations.

Awareness is raised with all employees through annual training and induction. Further awareness training is provided to all individuals involved directly in the above areas of responsibility. This policy is cascaded to our suppliers through their service agreements and our onboarding activities.

Relevant policies

The following policies are appropriate for the Modern Slavery Act.

Employee Team Charter

Our Team Charteris published on our website and forms part of our Employee Handbook. It explains the behaviours we expect from our teams, including the key tenets of the Act, while at work.

Whistleblowing Policy

We encourage all our employees to report any concerns relating to unlawful conduct, malpractice, dangers to the public or the environment, and any other matter of a serious nature. The Act is specifically referenced within our employee handbook.

Code of Conduct for Suppliers

We are committed to ensuring that our suppliers adhere to our Supplier Code of Conduct, which is incorporated into our framework agreements and published online. This includes demonstrating safe working conditions where necessary, treating workers with dignity and respect, and acting within the law in their use of labour. Serious violations will lead to the termination of our business relationship.  We use specified, reputable employment and recruitment agencies to source labour and verify the practices of any new agency we invite to act on our behalf. We cascade this Policy to our Tier 1 supply chain and introduce its content during onboarding.

Incident Management Reporting Policy

This provides guidance on reporting any cases of suspected modern slavery and SLAs for response and action.

Due diligence

We conduct due diligence when considering new suppliers and regularly review our existing suppliers. This due diligence includes:

  • evaluating the modern slavery risks of each new supplier as part of our onboarding process
  • conducting supplier audits through Sedex, where risks are identified (see risks below)
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through Sedex and requiring them to implement action plans

KPIs

We monitor the following KPIs and report to relevant bodies when required:

  • % of employees completing annual MS training.
  • % of Tier 1 supply chain companies completing MS awareness as part of onboarding or induction sessions

Risk notes

We currently have a higher level of monitoring in the following areas:

Countries

  • South Africa – Compliance and governance for small companies is lower than our standard.
  • India – staff and labour supply may have hidden slavery or bonded labour practices.

Review

This policy is reviewed annually.

Board Approval

This Modern Slavery Policy is made in the UK pursuant to section 54 of the Modern Slavery Act 2015 and is reviewed annually. It is published on our website at https://www.equalexperts.com/modern-slavery-policy/.

It has been approved by the Board of Directors of Equal Experts UK Ltd, who last reviewed it on 5 August 2026.

Sam McGregor, Chief Operating Officer