Handles Modern Slavery Policy

Handles Group Ltd

Modern Slavery and Human Trafficking Statement

Financial Year Ending: 31 December 2025
Approved by the Board on: 29/05/2025

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out the steps Handles Group Ltd ("**Handles," "we") has taken—and will continue to take—to prevent modern slavery and human trafficking within our business operations and supply chains.

1. Our Business & Structure

Handles Group Ltd is a private company registered in England & Wales (company number [___]) with approximately [<25] employees. We develop and provide a cloud‑based social‑media operating system for enterprise clients worldwide. Our operations consist of product development, customer success, sales, and administrative functions headquartered at Suite 5 Manor House, 1 Macauley Road, Broadstone, BH18 8AS, United Kingdom.

2. Our Supply Chains

Our supply chain is relatively simple and comprises:

• Cloud infrastructure providers (e.g., AWS, Microsoft Azure, Google Cloud) located in the UK/EU and the United States.

• Software‑as‑a‑Service vendors (customer‑support, analytics, payment processing, productivity tools).

• Professional services (legal, accounting, marketing agencies).

We do not manufacture physical goods and have no direct relationships with factories or high‑risk industries. Nonetheless, we recognise that modern slavery risks can arise at any tier of the supply chain.

3. Policies & Commitments

Handles is committed to operating ethically and with integrity. Our key policies include:

• Code of Conduct – requires all staff and contractors to act responsibly and lawfully.

• Supplier Code of Ethics – incorporates zero‑tolerance clauses for forced labour, slavery, and child labour.

• Whistle‑blowing Policy – provides a confidential channel to report concerns without fear of retaliation.

• Recruitment Policy – verifies the identity and legal right to work of all employees and contractors.

4. Due Diligence Processes

We conduct proportionate due diligence when onboarding new suppliers, including:

• Requiring confirmation of compliance with the Modern Slavery Act (or equivalent international law).

• Reviewing publicly available modern‑slavery or ESG statements where the supplier’s turnover exceeds the statutory threshold.

• Including contractual warranties prohibiting modern slavery and reserving audit rights.

For existing critical suppliers, we perform an annual desktop review and request updated modern‑slavery statements.

5. Risk Assessment & Management

During FY 2024 we carried out a risk‑mapping exercise that rated our supplier categories as low risk for modern‑slavery based on:

• Geographic location (majority in low‑risk, highly regulated jurisdictions).

• Service type (digital, professional services rather than labour‑intensive manufacturing).

We will reassess risks annually and enhance controls if our supply chain expands into higher‑risk regions or sectors.

6. Training & Awareness

All employees must complete an annual e‑learning module on modern slavery, covering:

• How to identify signs of forced labour or human trafficking.

• How to escalate concerns internally.

• Responsibilities under our Code of Conduct and UK law.

HR tracks completion rates and includes refresher training in onboarding for new hires.

7. Measuring Effectiveness

We monitor compliance through:

• Policy acknowledgements: 100 % of employees sign the Code of Conduct annually.

• Training completion: Target 100 % annually; FY 2024 achievement: 98 % (two late joiners completed in January 2025).

• Supplier attestations: All new Tier 1 suppliers have signed our Supplier Code of Ethics; no confirmed incidents reported in FY 2024.

8. Continuous Improvement

In FY 2025 we aim to:

1. Extend modern‑slavery questions to Tier 2 subcontractors where practical.

2. Add a modern‑slavery clause to all new non‑disclosure agreements.

3. Implement an independent hotline provider for whistle‑blowing.

9. Board Approval

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

William Roberts
Chief Executive Officer
Date: 29/05/2025

© Handles Group Ltd 2025