Modern Slavery Policy

MODULAR DATA LIMITED 

dated April 2024

Modular Data Ltd 

1. Purpose 

1.1. Our business, Modular Data Limited, is committed to combatting slavery and human trafficking  in its business and supply chains, and we make this statement to assist with compliance with  the Modern Slavery Act 2015. This statement relates to the financial year ending 31^st March  2024. 

1.2. As our business has a turnover of less than £36 million, we do not have a legal obligation to  produce a modern slavery statement. However: 

1.2.1. We agree that exploitation within all supply chains ending in the UK is a blight on our  society, and we are committed to playing our part in eliminating exploitation; 

1.2.2. We understand that customers with obligations under the Modern Slavery Act 2015  cannot comply with those duties without our cooperation.  

2. Statement 

2.1. To that end, we confirm that we have examined our own business and, to the extent that it is  reasonably practicable, businesses within our supply chain and we confirm the following:  

2.1.1. We confirm that within our own business, no relevant offence relating to slavery or  human tracking has been committed.  

2.1.2. We have made enquiries of businesses that supply directly to us and we are confident  that no relevant offence is committed in that business.  

2.2. Insofar as it was reasonably practicable, we have examined our supply chains and confirm that  we found no evidence of slavery or human trafficking. 

3. Scope 

3.1. Modular Data Limited provides consultancy and software development services for enterprises  and organisations within the United Kingdom and Europe. 

3.2. Our business : 

3.2.1. Has 2 full-time employees, 3 directors and 2 business subcontractors in the UK; 3.2.2. Has 10 or more limited company subcontractor organisations in the UK; 

3.2.3. Has 1 subcontractor organisation in Slovakia with 5 individuals working on software  development. 

3.3. We operate in the United Kingdom and the European Union.

3.4. We understand that certain industry sectors and geographical regions entail greater risk of  exploitation than others. We do not believe that our supply chain is in one of those sectors.  

3.5. Where it is reasonably practicable, we ensure that businesses in our supply chain have made a  similar statement relating to slavery and human trafficking. 

3.6. The person in our business responsible for assessing matters relating to slavery and human  trafficking is: Finbarr Murphy 

4. How we raise a concern 

4.1. We encourage all employees to report on any matters relating to slavery or human trafficking  in our supply chains of which they become aware. 

4.2. We encourage all employees and organisations in our supply chains to raise concerns about  any issue or suspicion of malpractice at the earliest possible stage. If employees have any other  queries or concerns, these should be raised with the managing director. 

5. Who is responsible for the policy ? 

5.1. The managing director has overall responsibility for ensuring this policy complies with our legal  and ethical obligations, and that all those under our control comply with it.  

5.2. The operations manager has primary and day-to-day responsibility for implementing this policy,  and for monitoring its use and effectiveness and dealing with any queries on its interpretation. 

5.3. Management at all levels are responsible for ensuring those reporting to them are made aware  of and understand this policy and are given adequate and regular training on it. 

6. Monitoring and review 

6.1. The operations manager will monitor the effectiveness and review the implementation of this  policy, regularly considering its suitability, adequacy and effectiveness. Any improvements  identified will be made as soon as possible. Internal control systems and procedures will be  subject to regular audits to provide assurance that they are effective in countering bribery and  corruption. 

6.2. All staff are responsible for the success of this policy and should ensure they use it to disclose  any suspected danger or wrongdoing.

6.3. Staff are invited to comment on this policy and suggest ways in which it operations manager.  

6.4. This policy does not form part of any employee’s contract of employment and it may be  amended at any time.