Modern Slavery and Human Trafficking Policy

Version: V5.0. Date: May 2026. Review: Annually by Executive Board.

1. Introduction

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

This anti-slavery and human trafficking policy is fully supported by the Executive Board.

Voluntary Publication

Under Section 54 of the Modern Slavery Act 2015, commercial organisations with an annual turnover of £36 million or more are required to publish an annual transparency statement. Agilexe’s current annual turnover is below this threshold, and the statutory obligation does not therefore apply. However, Agilexe publishes this policy voluntarily as a demonstration of our commitment to ethical business practice and in order to meet the expectations of our supply chain partners, including those operating under Ministry of Defence procurement frameworks.

2. Policy Statement

Agilexe strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all Agilexe employees, including Associates and contractors.

3. Agilexe Commitments

Agilexe expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery.

  • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
  • The prevention, detection and reporting of modern slavery in any part of our organization or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
  • We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risk-based approach we will also assess the merits of communicating our expectations to suppliers as part of Agilexe’s supplier due diligence process, which sets out the minimum standards required to combat modern slavery and trafficking.
  • Consistent with our risk-based approach, we may require:
    • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with Agilexe’s supplier due diligence process; and
    • Suppliers engaging workers through a third party to obtain that third party’s agreement to adhere to the same standards.
  • As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our expectations.
  • If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach, to terminating such relationships.
  • Agilexe will ensure that working hours are reasonable and comply with the law and industry standards.
  • Agilexe will not use child labour and will comply with all relevant laws in this regard. We do, however, support legitimate workplace apprenticeships, internships and other similar programmes that comply with applicable laws and regulations.
  • Agilexe will not use forced, bonded or involuntary labour and workers can leave after giving reasonable notice, with all wages owed to be paid.
  • All Agilexe employees will work in an environment that is both safe and healthy, in line with our Health and Safety Policy.
  • Agilexe prohibits physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation. Disciplinary and grievance procedures are clearly documented and communicated to all employees.
  • We recognise that all our employees have the right to form and join organisations of their own choosing, as long as it does not contravene Agilexe’s regulatory and independence requirements.
  • Agilexe is fully committed to eliminating discrimination in access to employment, training and working conditions, on grounds of race, colour, sex, age, religion, political opinion, national extraction, sexual orientation, disability or social origin, and to promoting equality of opportunity and treatment as outlined in the Agilexe Equality and Diversity Policy.
  • Agilexe will provide written and clear contracts which detail the terms and conditions of employment. We will ensure that work performed by employees is on the basis of recognised employment law and practice.
  • Where a human rights violation is identified, we will work with all parties involved to ensure victims have access to remedy, compensation and justice. We will also investigate the root cause so that we can take appropriate steps to prevent such a violation reoccurring.

Recruitment and Agency Due Diligence

Agilexe applies due diligence at the point of engagement when using recruitment agencies or other third-party labour providers. We will take reasonable steps to satisfy ourselves that any agency we use complies with applicable employment law, does not exploit workers, and operates transparent recruitment practices. Where concerns are identified, we will raise them directly with the agency and will not engage with suppliers who cannot demonstrate compliance.

4. Reporting

Anyone with concerns about modern slavery, human trafficking, or related issues within Agilexe or its supply chain should report them promptly. Concerns can be raised through the following channels:

  • Email: info@agilexe.co.uk
  • Modern Slavery Helpline: If you prefer to report to an external body, the government’s Modern Slavery Helpline is available on 0800 0121 700 (free, 24 hours a day, 7 days a week). You can also report online at www.modernslavery.co.uk.

Agilexe will not subject any individual to detrimental treatment as a result of raising a concern in good faith under this policy, even if the concern is subsequently found to be mistaken.

5. Review

This anti-slavery and human trafficking policy is to be reviewed annually by the Executive Board, who will ensure that any changes are clearly communicated to all staff and other stakeholders.

Where appropriate, third parties may be sought to assist in the review process and to assist with the communication of changes to stakeholders outside Agilexe.

Agilexe is committed to reviewing the performance of its employees in the monitoring of modern slavery in the supply chain and will schedule routine annual awareness training for all employees to ensure they can recognise signs of modern slavery and understand their reporting obligations.

Agilexe | Anti-Slavery and Human Trafficking Policy V5.0 | May 2026