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Modern Slavery Policy

Modern Slavery and Human Trafficking Statement

 

1. Introduction

 

This Modern Slavery and Human Trafficking Statement is made on behalf of Gresham Technologies Ltd and affiliates (Gresham or the Group) pursuant to section 54 of the UK Modern Slavery Act 2015. It sets out the steps taken during the reporting period to prevent modern slavery and human trafficking in our business operations and supply chains.

The Gresham group is committed to corporate sustainability and to a principled approach of doing business. We recognise that we have a duty to manage our business affairs and operations in a sustainable and responsible manner. We attribute the utmost importance to our corporate values and to our environment, social and governance (ESG) policies.

Our respect for human rights is guided by the principles set out in the United Nations Universal Declaration of Human Rights. We believe modern slavery is a crime and a violation of fundamental human rights.

Modern slavery can take various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

Gresham has a zero-tolerance approach to modern slavery and is committed to acting ethically, transparently, and with integrity in all business dealings and relationships. We recognise our responsibility to respect human rights and to implement and enforce effective systems and controls to minimise the risk of modern slavery.

2. Our Organisation, Structure and Operations

 

Gresham is a private company headquartered in the United Kingdom, providing enterprise software and data automation solutions to financial institutions and other regulated organisations globally.

The Group operates through subsidiaries and branch offices across multiple jurisdictions, including the United Kingdom and other international locations. Our core activities include software development, licensing, cloud services, implementation services, and customer support.

Our workforce consists primarily of professional and technical employees, supplemented where appropriate by contractors, consultants, and specialist service providers.

3. Our Supply Chains

 

Gresham’s supply chain primarily consists of suppliers providing:

  • Technology and cloud infrastructure services

  • Software and data services

  • Professional and consulting services

  • Recruitment and staffing services

  • Office, facilities, and business support services

While our supply chains are largely service-based and lower risk than manufacturing supply chains, we recognise that modern slavery risks can still arise, particularly in outsourced services, recruitment, facilities management, and extended subcontracting chains.

We conduct due diligence checks on suppliers to ascertain their attitude to modern slavery and minimise the risk of modern slavery occurring in our supply chain. Where possible, suppliers are required to provide declarations and contractual representations regarding the absence of modern slavery in their organisation and their supply chain.

Our policy is not to work with suppliers who we know to be or have been involved in modern slavery. We will take steps to terminate and disassociate ourselves with any supplier that we find or suspect to have any modern slavery in their organisation or in their supply chain.

Where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.

Anyone involved in sourcing, procurement and supplier management is required to pay particular regard to the working practices of suppliers and to report any instances or risks of modern slavery to Gresham.

4. Policies in Relation to Modern Slavery

 

During the reporting period, Gresham maintained and enforced internal policies designed to prevent modern slavery and unethical labour practices, including:

  • This statement

  • Human Rights Policy

  • Codes of Conduct and Business Ethics Policies

  • Supplier onboarding and procurement controls

  • Whistleblowing (Speak Up) Policy

  • ESG and corporate governance policies

Our Modern Slavery Policy applies to all employees, officers, directors, contractors, consultants, agency workers, and business partners. It establishes a zero-tolerance approach and requires the reporting of any suspected or actual modern slavery concerns.

These policies are communicated to staff and made available internally. Key policies are also communicated to relevant suppliers and business partners.

5. Due Diligence Processes

 

During the reporting period, we continued to apply due diligence measures intended to reduce the risk of modern slavery in our business and supply chain, including:

  • Risk-based supplier onboarding checks

  • Supplier due diligence questionnaires where appropriate

  • Appropriate contractual clause and reviews of applicable vendor policy statements

  • The right to terminate supplier relationships where modern slavery risks are identified and not appropriately addressed

Our procurement and legal teams support supplier engagement and contract controls to ensure that modern slavery requirements are incorporated into relevant supplier agreements.

6. Risk Assessment and Risk Management

 

Gresham assesses modern slavery risk by considering:

  • The nature of services provided

  • Supplier type and sector

  • Geographic location of suppliers and delivery centres

  • Use of subcontracting and temporary labour

As a software and services business, we consider our direct employee base to be lower risk than high-risk sectors such as manufacturing, agriculture, or construction. However, we recognise potential exposure in certain supplier categories, including staffing, facilities, and outsourced services.

Where higher-risk indicators are identified, enhanced due diligence and contractual controls may be applied.

7. Effectiveness and Monitoring

 

To assess the effectiveness of our modern slavery controls, Gresham monitors:

  • Completion of supplier due diligence steps in onboarding

  • Inclusion applicable contractual clauses in supplier contracts

  • Reports made through whistleblowing channels

  • Policy review and update cycles

  • Training completion rates

During the reporting period, no substantiated incidents of modern slavery were identified within our direct operations. Any reported concerns would be investigated and addressed in accordance with internal policies and legal obligations.

We continue to review and enhance our controls as part of our broader ESG and risk management framework.

8. Training and Awareness

 

Gresham provides modern slavery awareness training as part of employee induction processes. Additional targeted training is provided to employees in roles with greater exposure to supplier engagement and procurement activities.

Training covers:

  • Understanding modern slavery risks

  • Identifying potential indicators

  • Reporting obligations and channels

  • Supplier-related risk awareness

Training materials are periodically reviewed and updated.

9. Reporting Concerns

 

We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your line manager immediately or the People & Culture team. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

10. Compliance

 

All persons to whom this policy applies must read, understand, and comply with this policy.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Any supplier who is found to have operated in a manner that is not consistent with this policy may be terminated.

11. Responsibility & Approval

 

The board of directors has overall responsibility for ensuring this policy complies with our legal obligations. Day-to-day management of this policy is devolved to the Legal team, who are responsible for implementing and enforcing effective systems in accordance with applicable laws (including the Modern Slavery Act 2015). Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

This statement has been approved by the Group Board of Directors and is signed on its behalf by:

Mark Hepsworth

Title: CEO

Date: 1 February 2026

This statement will be reviewed and updated annually and published on the Group’s website in accordance with the UK Modern Slavery Act 2015.