Modern Slavery and Human Trafficking Policy Statement

Digitator has zero tolerance for modern slavery, forced labour, servitude, child labour and human trafficking in its business activities and supply chains.

1. Purpose and commitment

Modern slavery is a serious crime and a violation of fundamental human rights. It includes slavery, servitude, forced or compulsory labour, child labour and human trafficking, in which a person is deprived of freedom or exploited for personal or commercial gain.

Digitator Limited is committed to acting ethically and with integrity in its business relationships and to using proportionate controls to reduce the risk of modern slavery in its own activities and supply chains.

Digitator does not currently meet the annual turnover threshold at which section 54 of the Modern Slavery Act 2015 requires publication of an annual modern slavery statement. This policy statement is therefore published voluntarily. Digitator will reassess its legal obligations if its size, structure or activities change.

2. Business structure and supply chains

Digitator is a small, director-led UK digital consultancy. It has one principal worker, the Director, who personally completes the majority of client work. Services are primarily professional, computer-based and delivered remotely, with occasional work at client premises.

Digitator may engage specialist subcontractors for defined elements of work where additional expertise or capacity is required. The Director retains responsibility for supplier and subcontractor selection, client delivery, quality assurance and compliance with agreed contractual requirements.

Digitator’s principal supply-chain relationships comprise:

  • Independent specialist subcontractors and professional advisers;
  • Software, analytics, research and cloud-service providers;
  • Email, communications, hosting and data-storage providers; and
  • Computer hardware, office equipment and general business suppliers.

The business does not manufacture physical products, operate labour-intensive facilities or routinely procure temporary or low-skilled labour.

3. Scope

This policy applies to the Director and to any subcontractor, freelancer, consultant, supplier or other person engaged to provide goods or services to Digitator. Relevant expectations will be communicated proportionately according to the nature, location and risk of the work or supply arrangement.

This policy does not form part of any contract of employment or engagement, and Digitator may amend it when business, legal or risk circumstances change.

4. Responsibility and governance

The Director has overall responsibility for this policy and for ensuring that Digitator’s arrangements remain proportionate to its size and risk profile. The Director will:

  • Assess modern-slavery risks in material supplier and subcontractor relationships;
  • Carry out proportionate checks before appointing subcontractors or higher-risk suppliers;
  • Communicate relevant standards and contractual requirements;
  • Consider and investigate concerns promptly and impartially;
  • Take corrective action where a concern is substantiated; and
  • Review this policy and its effectiveness at least annually.

Anyone working for or on behalf of Digitator is expected to cooperate with these arrangements and raise suspected breaches or warning signs promptly.

5. Risk assessment

Digitator’s direct modern-slavery risk is considered low because the business consists of one Director providing skilled professional services. Its supply chain is limited and does not normally involve the direct employment or management of vulnerable, migrant, temporary or low-paid labour.

The risk is not treated as zero. Factors that may increase risk include:

  • Subcontracted services involving further undisclosed subcontracting;
  • Suppliers operating in countries, sectors or labour markets with recognised exploitation risks;
  • Unusually low prices, opaque payment arrangements or unclear employment status;
  • A supplier’s unwillingness to explain its workforce or supply-chain practices;
  • Use of labour brokers, recruitment fees or restrictions on workers’ freedom; and
  • Hardware and electronic equipment supply chains involving complex international sourcing.

The Director will consider these factors when selecting and reviewing suppliers. The depth of due diligence will reflect the nature, value, location and risk of the relationship.

6. Due diligence and selection

Before engaging a subcontractor or a supplier presenting elevated risk, Digitator may:

  • Verify the identity, business status, ownership and relevant experience of the provider;
  • Confirm who will perform the work and whether any further subcontracting is proposed;
  • Review applicable policies, published modern-slavery statements, codes of conduct or certifications;
  • Ask about recruitment, pay, working conditions and the use of labour intermediaries where relevant;
  • Check for credible adverse information, regulatory action or substantiated labour-rights concerns;
  • Assess whether fees, timescales and working expectations are realistic and support lawful working practices; and
  • Record the decision and any additional controls required.

Digitator will favour reputable providers that demonstrate transparent, lawful and ethical working practices. Existing relationships will be reconsidered if new information materially changes their risk profile.

7. Standards for subcontractors and suppliers

Digitator expects subcontractors and relevant suppliers to:

  • Comply with applicable laws relating to modern slavery, human trafficking, child labour, employment and worker protection;
  • Ensure that work is undertaken voluntarily and that workers are free to leave in accordance with lawful contractual terms;
  • Not retain identity documents, charge improper recruitment fees or use threats, coercion or deceptive recruitment practices;
  • Provide lawful, safe and fair working arrangements;
  • Communicate equivalent expectations to any approved subcontractors or material suppliers they use;
  • Report suspected modern slavery connected with work for Digitator without delay; and
  • Cooperate with reasonable enquiries or corrective action.

Where proportionate, these requirements will be reflected in onboarding information, purchase terms or subcontractor agreements. Subcontracting of client work must also comply with any client approval, confidentiality, data protection and security requirements.

8. Raising concerns and protection from retaliation

Anyone who believes that modern slavery may be occurring in Digitator’s activities or supply chain should raise the concern with the Director as soon as possible. A person does not need proof before reporting a genuine concern and should not investigate a potentially dangerous situation personally.

Reports should include, where safely available:

  • The organisation, activity or people involved;
  • What was observed or reported;
  • Relevant dates, locations and supporting information; and
  • Whether anyone appears to be in immediate danger.

Digitator will handle concerns as sensitively and confidentially as reasonably possible. No person will be disadvantaged for raising a genuine concern in good faith, even if it is not substantiated. If someone appears to be in immediate danger, the emergency services should be contacted.

9. Investigation, response and remediation

The Director will assess any concern promptly, preserve relevant information and decide whether specialist advice, client notification or referral to an appropriate authority is required. Digitator will prioritise the safety and welfare of potential victims and will avoid action that could place them at greater risk.

Where a concern is substantiated, proportionate action may include:

  • Requiring an improvement or remediation plan with defined timescales;
  • Increasing monitoring or suspending new work;
  • Requiring the removal of an unapproved subcontractor;
  • Notifying an affected client or appropriate authority; or
  • Ending the supplier or subcontractor relationship where remediation is not credible, safe or effective.

Decisions will consider the possible effect on affected workers. Immediate termination will not be treated as the automatic response if it could worsen harm, but Digitator reserves the right to terminate a relationship for a serious breach, subject to contractual and legal obligations.

10. Communication, training and awareness

The Director will maintain awareness of relevant modern-slavery risks and guidance appropriate to Digitator’s activities. This policy will be made available through Digitator’s website and provided to subcontractors and relevant suppliers as appropriate.

If Digitator engages employees or materially expands its use of subcontractors, it will introduce proportionate induction, training and refresher arrangements for people involved in procurement, supplier management or delivery.

11. Monitoring and indicators of effectiveness

Digitator will monitor the practical application of this policy using proportionate indicators, including:

  • The proportion of new subcontractors and higher-risk suppliers subject to documented screening;
  • The proportion of relevant agreements containing modern-slavery and ethical-working expectations;
  • The number and nature of concerns raised, investigations undertaken and corrective actions completed;
  • Any supplier or subcontractor relationship suspended or ended for a related concern; and
  • Completion of the annual policy and risk review.

The absence of reported concerns will not by itself be treated as proof that controls are effective. The Director will consider whether reporting routes are understood and whether changes in services, suppliers or geography create new risks.

12. Review, transparency and approval

This policy statement will be reviewed at least annually and sooner following a substantiated concern, a material change in Digitator’s structure or supply chain, or a relevant change in law or client requirements. Future versions will describe material actions taken and improvements planned.

13. Contact

Questions, concerns or reports relating to this policy should be directed to:

Last reviewed: 4 September 2026
Next review date: 3 September 2027