Modern Slavery Act Statement | Gradio Safety LTD

// table of contents

1.  Statement purpose and legal basis2.  Our commitment3.  Organisational structure and business model4.  Our supply chain5.  Modern slavery risks in our operations and supply chain6.  Due diligence processes7.  Policies and governance8.  Training and awareness9.  Key performance indicators (KPIs)10. Actions taken this financial year11. Planned actions for next financial year12. Reporting concerns (whistleblowing)13. Board approval and sign-off14. Contact us

1. Statement purpose and legal basis

This statement is made under Section 54 of the Modern Slavery Act 2015, which requires commercial organisations that supply goods or services and have a turnover of £36 million or more to produce a slavery and human trafficking statement for each financial year.

// legal status of this statement
→ Gradio Safety LTD's turnover is currently below the £36 million threshold
→ We are therefore NOT legally required to publish a Modern Slavery Act statement
→ We publish this statement VOLUNTARILY as a demonstration of our commitment
→ We believe that all companies, regardless of size, have a responsibility to prevent modern slavery
→ This statement follows the statutory guidance format for voluntary statements

2. Our commitment

Gradio Safety LTD has a zero-tolerance approach to modern slavery, forced labour, child labour, and human trafficking in all its forms. We are committed to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to ensure modern slavery is not taking place anywhere in our operations or supply chain.

We expect the same high standards from all our contractors, suppliers, and business partners. We will not knowingly work with any organisation that is involved in modern slavery or human trafficking, and we will terminate relationships where we discover such practices.

3. Organisational structure and business model

Attribute	Details
Company name	Gradio Safety LTD
Company number	17456330 (registered in England and Wales)
Registered office	England, United Kingdom
Business type	Private limited company
Industry	IT consulting — software architecture, security audits, compliance consulting
Business model	Knowledge-based professional services. We sell expertise, not physical goods. No manufacturing, no logistics, no physical supply chain.
Employees	Small team of UK-based professionals. All staff are engaged under UK employment law with contracts that comply with the Employment Rights Act 1996 and National Minimum Wage Act 1998.
Operating locations	United Kingdom only. No offshore operations, no international offices, no operations in high-risk jurisdictions.
Turnover	Below £36 million (below the mandatory reporting threshold — this statement is voluntary)
Clients	UK and international businesses and individuals purchasing architecture consultation packages (€100–€500) or custom engagements

4. Our supply chain

Our supply chain is limited to digital services and professional tools. We do not source physical goods, raw materials, or manufactured products. This inherently limits our exposure to modern slavery risk, as the sectors most associated with modern slavery (agriculture, construction, manufacturing, textiles, mining) are not part of our supply chain.

Our suppliers fall into the following categories:

Category	Suppliers	Modern slavery risk	Reason
Payment processing	Authorized payment & banking providers	Very low	FCA-regulated financial institutions with their own modern slavery statements and ESG programmes
Cloud infrastructure	Vercel, Cloudflare	Very low	US-headquartered technology companies with published modern slavery statements and ethical sourcing policies
Software tools	Google (Workspace, Analytics), GitHub, Notion	Very low	Large technology companies with comprehensive human rights policies and modern slavery statements
Professional services	UK-based accountant, UK-based legal advisor	Very low	UK-regulated professionals operating under UK employment law
Subcontractors	None currently. If subcontractors are engaged in the future, they will be subject to the due diligence process in Section 6.	N/A	No subcontractors used at present

5. Modern slavery risks in our operations and supply chain

5.1 Our operations

The risk of modern slavery in our own operations is extremely low because:

All staff are UK-based professionals engaged under UK employment law
All staff are paid above the UK National Minimum Wage and National Living Wage
All staff have written employment contracts compliant with the Employment Rights Act 1996
No staff are recruited from overseas or through third-party labour agencies
No staff work in sectors or conditions associated with forced labour
We do not use agency workers, zero-hours contracts, or gig-economy labour
All staff have the right to work in the UK (verified under UK immigration law)

5.2 Our supply chain

The risk of modern slavery in our supply chain is very low because:

We do not source physical goods — no exposure to high-risk sectors (agriculture, construction, manufacturing, textiles, mining)
All our suppliers are large, publicly listed or venture-backed technology companies with their own modern slavery statements
All our suppliers are headquartered in the UK, US, or other low-risk jurisdictions
No suppliers operate in countries on the Global Slavery Index top 10 list
Our professional services suppliers (accountant, legal) are UK-regulated

5.3 Risk areas we monitor

Despite the low risk, we remain vigilant in the following areas:

Cloud infrastructure hardware: Our cloud providers (Vercel, Cloudflare) run on hardware manufactured by companies with global supply chains. We rely on our providers' own modern slavery statements to address this indirect risk.
Payment processing: Regulated payment gateways operate globally, with published modern slavery statements and ESG programmes.
Future subcontractors: If we engage subcontractors in the future, they will be subject to the due diligence process in Section 6.
Future expansion: If we expand into new markets or services, we will reassess our modern slavery risk profile.

6. Due diligence processes

We apply the following due diligence process to all new suppliers and sub-processors:

Step	Action	When
1. Pre-contract screening	Assess the supplier's country of operation, sector, and ownership. Check against the Global Slavery Index and UK Government's list of high-risk countries.	Before onboarding
2. Policy review	Request and review the supplier's modern slavery statement (if applicable), human rights policy, and labour standards policy.	Before onboarding
3. Certification check	Verify relevant certifications (e.g., ISO 27001, SOC 2) which include security and ethical requirements. Check for any modern slavery convictions or enforcement actions.	Before onboarding
4. Contractual terms	Include anti-slavery clauses in contracts requiring suppliers to comply with the Modern Slavery Act 2015 and to notify us of any modern slavery concerns.	At contract signing
5. Ongoing monitoring	Review suppliers' modern slavery statements annually. Monitor for adverse news, enforcement actions, or changes in ownership/operations.	Annual
6. Escalation	If a modern slavery concern is identified, escalate to the Board immediately. Suspend the relationship pending investigation. Terminate if confirmed.	As needed

7. Policies and governance

The following policies support our anti-slavery commitment:

Policy	Relevance to modern slavery
This Modern Slavery Act Statement	Primary policy — sets out our commitment, due diligence, and reporting
Compliance Overview	Central compliance register — includes modern slavery in the risk management framework
KYC & AML Policy	Client and supplier due diligence — includes ownership checks that help identify potential slavery risks
Privacy Policy	Data protection — ensures whistleblower reports are handled confidentially
Whistleblowing / Speak-Up Policy	Enables staff and partners to report modern slavery concerns without retaliation (see Section 12)
Recruitment Policy	Ensures all staff have the right to work in the UK, are paid at or above the National Minimum Wage, and have written employment contracts
Supplier Code of Conduct	Sets out the ethical standards we expect from suppliers, including zero-tolerance for modern slavery

7.1 Governance responsibility

Role	Modern slavery responsibility
Board of Directors	Ultimate accountability. Approves this statement annually. Oversees the anti-slavery programme.
Compliance Officer / DPO	Day-to-day responsibility. Conducts supplier due diligence, maintains the risk register, coordinates training, handles reports.
All staff	Required to complete training, remain vigilant, and report any concerns through the whistleblowing channel.

8. Training and awareness

All staff receive modern slavery awareness training as part of their induction and annual refresher training. The training covers:

What modern slavery is: Forced labour, child labour, human trafficking, debt bondage, descent-based slavery, forced marriage
The Modern Slavery Act 2015: Key provisions, Section 54 reporting requirements, criminal offences
Red flags and warning signs: Signs of exploitation in colleagues, suppliers, and clients — restricted movement, withheld passports, debt dependency, isolation, poor working conditions
High-risk sectors and countries: Sectors (agriculture, construction, manufacturing, textiles, mining, hospitality) and countries on the Global Slavery Index
How to report: Internal whistleblowing channel, external reporting to the Modern Slavery Helpline (08000 121 700) or police
Our policies: This statement, the Supplier Code, the Whistleblowing Policy, and the non-retaliation commitment

Training completion is recorded and retained for 5 years. The training is reviewed annually and updated to reflect emerging risks and regulatory guidance.

9. Key performance indicators (KPIs)

We measure the effectiveness of our anti-slavery programme using the following KPIs:

KPI	Target	This year
Staff training completion rate	100%	100% (all staff completed induction training)
Suppliers screened for modern slavery risk before onboarding	100%	100% (all 7 sub-processors screened)
Suppliers with modern slavery statements reviewed annually	100%	100% (all applicable suppliers reviewed)
Modern slavery concerns reported	0 (zero tolerance)	0 (no concerns identified)
Suppliers terminated due to modern slavery	0 (zero tolerance)	0 (no terminations required)
This statement reviewed and approved by the Board	Annual	Approved 28 August 2026

10. Actions taken this financial year

Published this voluntary Modern Slavery Act Statement on our website
Conducted modern slavery risk assessment of all key technology sub-processors (Cloudflare, Vercel, Google, GitHub, Notion) — all assessed as very low risk
Reviewed modern slavery statements of all applicable suppliers
Delivered modern slavery awareness training to all staff as part of induction
Included modern slavery in the compliance risk register (see Compliance Overview Section 12)
Established whistleblowing channel for reporting modern slavery concerns
Verified all staff have the right to work in the UK and are paid above the National Minimum Wage

11. Planned actions for next financial year

Review and update this statement (August 2027)
Conduct annual refresher training for all staff
Re-review all suppliers' modern slavery statements
Develop a formal Supplier Code of Conduct document (if not yet published)
Assess whether any new suppliers or subcontractors are needed and apply the due diligence process
Monitor regulatory developments and update this statement if guidance changes
Consider joining a relevant industry initiative or working group on ethical sourcing

12. Reporting concerns (whistleblowing)

We encourage all staff, contractors, clients, suppliers, and members of the public to report any concerns about modern slavery in our operations or supply chain.

Internal reporting: Email info@gradiosafetyltd.com with "Confidential — Modern Slavery Concern" in the subject line. Reports are handled by the Compliance Officer and treated in strict confidence.
Anonymous reporting: You may report anonymously. All reports are investigated regardless of whether you identify yourself.
Non-retaliation: We do not tolerate retaliation against anyone who raises a concern in good faith. Retaliation is a disciplinary offence.
Modern Slavery Helpline: You can also report concerns externally to the Modern Slavery Helpline on 08000 121 700 or at modernslaveryhelpline.org.
Police: In emergencies, call 999. For non-emergencies, call 101 or report online to your local police force.
Home Office: Report suspected modern slavery to the Home Office via the UK Modern Slavery reporting system.

// response commitment
→ We acknowledge all internal reports within 2 business days
→ We conduct an initial assessment within 5 business days
→ We provide a substantive response within 14 business days
→ If a concern is substantiated, we take immediate action — up to and including terminating the supplier relationship and reporting to the authorities

13. Board approval and sign-off

This Modern Slavery Act Statement was approved by the Board of Directors of Gradio Safety LTD on 28 August 2026 and is signed on behalf of the Board by:

// signed
→ Gradio Safety LTD
→ Company No. 17456330
→ Approved by the Board of Directors: 28 August 2026
→ Next review date: August 2027
→ Published on: gradiosafetyltd.com/modern-slavery-act

This statement has been published on our website and will remain accessible for the duration of the financial year. It will be reviewed and updated annually.

14. Contact us

For questions about this Modern Slavery Act Statement, to request additional information, or to report a concern:

Email: info@gradiosafetyltd.com
Subject line: "Modern Slavery Act Statement" or "Confidential — Modern Slavery Concern"
Company: Gradio Safety LTD, Company No. 17456330, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Modern Slavery Helpline: 08000 121 700 — modernslaveryhelpline.org
Related policies: Compliance Overview · KYC & AML Policy · Privacy Policy

// version history

v2.0  2026-08-28  Full rewrite — Section 54 compliant format: organisational structure, supply chain mapping, risk assessment, due diligence process, policies, training, KPIs, actions taken, planned actions, whistleblowing, board sign-offv1.0  2026-08-27  Initial Modern Slavery Act Statement