Modern Slavery Policy

 

Modern Slavery Policy
Version 1.0 | Issued: 29/05/2025

Introduction
Fluid IT Consulting Ltd (“Fluid”) is a digital transformation consultancy working with a network of UK-based subcontractors and directly employing a growing team of permanent staff and contractors. We maintain a zero-tolerance approach to all forms of modern slavery, including servitude, forced or compulsory labour, and human trafficking.

This policy outlines the steps Fluid takes to prevent modern slavery within our business and across our supply chain. It supports our commitment to upholding the principles of the Modern Slavery Act 2015 and will inform our annual Slavery and Human Trafficking Statement.

1. Commitment and Principles
Fluid respects fundamental human rights and is committed to the principles outlined in the United Nations Universal Declaration of Human Rights. We support the effective elimination of compulsory labour and child labour in all forms.

We expect all individuals and organisations we work with — including employees, contractors, suppliers, and delivery partners — to uphold equivalent standards and share our zero-tolerance approach to modern slavery.

2. Purpose of this Policy
2.1 This policy aims to prevent opportunities for modern slavery to occur within Fluid’s operations or those of our UK-based suppliers.
2.2 We act with integrity in all our business dealings and relationships and implement robust systems and controls to ensure modern slavery does not take place in any part of our business or wider supply chain.

3. Prevention Measures
Fluid is committed to ensuring transparency and will take the following steps to prevent modern slavery:

  • Conduct periodic risk assessments to identify any parts of our business or supply chain at greater risk of modern slavery.

  • Engage with all suppliers and subcontractors to share this policy and understand their measures for preventing modern slavery in their operations.

  • Include appropriate provisions in contracts and agreements, requiring suppliers to:

    • Confirm adherence to this policy;

    • Cascade equivalent obligations to their own supply chains;

    • Accept Fluid’s right to audit compliance, should reasonable concerns arise.

  • Where relevant, introduce supplier pre-screening and self-reporting as part of our onboarding process.

  • Support the legal employment of young workers in accordance with UK law, including protection from hazardous roles, unsociable hours, and wage exploitation.

4. Responsibility for the Policy
4.1 The Fluid leadership team has overall responsibility for ensuring this policy is implemented effectively and in line with legal and ethical standards.
4.2 Managers are responsible for:

  • Communicating this policy to their teams and suppliers;

  • Ensuring team members understand and comply with the policy;

  • Identifying training needs where relevant.

5. Reporting Concerns
5.1 All team members are encouraged to report any suspicion or evidence of modern slavery within Fluid or among our suppliers. Concerns can be raised in confidence with their line manager or via email at: info@fluiditconsulting.co.uk
5.2 We also welcome concerns raised by individuals outside the business. All concerns will be taken seriously and investigated appropriately.
5.3 We support and protect anyone who raises a concern in good faith. No one will suffer any detrimental treatment for doing so. While anonymous reports are accepted, named concerns are encouraged to help ensure thorough investigation and response.

6. Breaches of this Policy
6.1 If an instance of modern slavery is identified, we will work with the relevant party to agree a corrective action plan.
6.2 Where a breach is not resolved to our satisfaction or poses significant risk, Fluid reserves the right to suspend or terminate the relationship.

7. Communication and Awareness
7.1 This policy is communicated to all suppliers, contractors and business partners at the outset of our relationship and is reinforced periodically.
7.2 It is made available to all employees and contractors and will be included in relevant training and onboarding materials.

8. Review
8.1 This policy will be reviewed at least annually by the leadership team and updated where necessary. It will inform our publicly available Modern Slavery and Human Trafficking Statement.