Modern Slavery and Human Trafficking Statement

Updated 01/09/2021


This Modern Slavery and Human Trafficking Statement is aresponse to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates toactions and activities for the financial year ending 31 October2021. Ltd ('the Company', 'we', 'us' or'our') is committed to preventing slavery and human trafficking violationsin its own operations, its supply chain, and its products. We havezero-tolerance towards slavery and require our supply chain to comply with ourvalues. 

Organisational structure Ltd is the subsidiary of the RedhairGroup group, the parent company being Redhair HoldingsLtd and has business operations in the United Kingdom.

We operate in the Software Development sector.The nature of our supply chains is as follows: We work with a singleoverseas supplier who supply us services such as outsourced development.


For more information about the Company, please visitour website:

Due Diligence

As part of our efforts to monitor and reduce the risk ofslavery and human trafficking occurring in our supply chains, we have adoptedthe following due diligence procedures: 

·   Internal supplier audits.

Our due diligence procedures aim to:

·   Identify and action potential risks in ourbusiness and supply chains.

·   Monitor potential risks in our business andsupply chains

·   Reduce the risk of slavery and human traffickingoccurring in our business and supply chains.

Risk and compliance

The Company has evaluated the nature and extentof its exposure to the risk of slavery and human traffickingoccurring in its UK supply chain through:

·   Evaluating the slavery andhuman trafficking risks of each new supplier.

·   Reviewing on a regular basisall aspects of the supply chain based on supply chain mapping.

We consider that we operate in a high-risk environmentbecause the majority of our supply chain is based in the UK and inlow-risk industries, such as internet software and services.

We do not tolerateslavery and human trafficking in our supply chains. Where there is evidence offailure to comply with our procedures by any of our suppliers, wewill seek to terminate our relationship with that supplier immediately.


TheCompany uses Key Performance Indicators (KPIs)to measure its effectivenessand ensure that slavery and human trafficking is not taking place in its business and supply chains.These KPIs are as follows:

·   We will contact suppliers toenquire about their modern slavery practices every 6 months.

·   We will train our staff aboutmodern slavery issues and increase awareness within the Company.

·   We will carry out a regularaudit of suppliers - 10% ofsuppliers each year.

Training our staff

The Company requires its staff to completetraining and ongoing refresher courses on slavery and humantrafficking. The Company's training covers:

·   How to identify the signs of slavery and humantrafficking.

·   What initial steps should be taken if slavery orhuman trafficking is suspected.

·   How to escalate potential slavery or humantrafficking issues to the relevant parties within the Company.

·   What external help is available.

·   What steps the Company should take ifsuppliers in its supply chain do not implement anti-slavery policiesin high-risk scenarios, including their removal from theCompany's supply chain.


The statement was approved by the board of directors.




Alex Stevens, Director Ltd



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