Austin Elliot's Modern Slavery Statement

Modern Slavery Statement

This Modern Slavery Statement is published voluntarily by Austin Elliot Consultancy Ltd (‘AE’) as part of its commitment to ethical business practice and the prevention of modern slavery and human trafficking.

This statement is made with reference to section 54(1) of the Modern Slavery Act 2015 and sets out the steps taken by AE during the financial year ending 31 March 2026 to prevent modern slavery and human trafficking within our operations and supply chains.

About us

AE provides consultancy services across both the public and private sectors. While these sectors are not generally considered high-risk for modern slavery, we recognise that risks may still exist within complex supply chains and service delivery arrangements. We are committed to identifying, assessing, and mitigating these risks wherever they may arise.

No instances of modern slavery have been identified in our operations or supply chains and the following steps have been taken:

• Measures put in place to identify and assess the potential risks in our supply chains.
• Reviewed our supplier contracts to include termination powers if the supplier is, or is suspected to be, involved in modern slavery.
• Provided training and education to our employees on the legislation, embedding a zero-tolerance policy towards modern slavery and designed a process for incident reporting.
• Publicised our modern slavery statement on our website.
• Prioritised ethical and responsible business practices and written this into our Code of Practice for all employees to adhere to.

We take our responsibility to prevent modern slavery and trafficking within our supply chain seriously and have written a number of key aims for us to focus attention on. These aims will help to ensure that we are enhancing awareness of modern slavery risks and compliance with our policies and standards within our own business, and that we are carrying out specific due diligence within our supply chains and driving compliance with our standards.

• Expanding our supplier due diligence checks, including evaluating them on their approach to risk; environmental sustainability; health and safety; and modern slavery.
• Reviewing our purchasing practices to ensure that we are not putting undue pressure on suppliers that may increase the risk of human rights issues.
• Taking steps to embed human rights risk factors into our client acceptance process, putting a requirement on our people to perform additional research on all clients.
• We recognise the importance of staff awareness in identifying and reporting potential modern slavery risks. Our Code of Practice, which includes guidance on ethical conduct and reporting concerns, is introduced to all employees during their induction and is refreshed with all staff on an annual basis

 Our anti-modern slavery initiatives are part of our wider social value strategy and sustainability goals that help achieve this purpose. We will not tolerate any form of human rights abuse within our business or supply chains. Our Sustainable Procurement Policy can be found on our website.

 Our policies and governance

 AE is committed to conducting business ethically and responsibly. Our approach is supported by internal policies and procedures, including:

• Code of Practice
• Equality, Diversity & Inclusion Policy
• Dignity at Work Policy
• Anti-harassment and Bullying Policy
• Whistleblowing / reporting procedures

Our Code of Practice sets out the standards expected of all employees, including a clear obligation to act ethically and report any concerns. All employees are required to confirm their understanding and compliance with the Code.

Any breach of the Code is taken seriously and may result in disciplinary action, up to and including termination of employment.

Supply chain due diligence and procurement

AE ensures that suppliers are engaged fairly, professionally and in accordance with applicable UK law and principles of responsible procurement.

Our standard supplier contracts include provisions relating to modern slavery and human trafficking, including:

• an obligation to comply with applicable laws, including the Modern Slavery Act 2015
• the right for AE to terminate contracts where a supplier is found or reasonably suspected to be in breach of the Act
• requirements for suppliers to maintain appropriate oversight of their own supply chains and subcontractors

We also require suppliers to ensure that individuals providing services on our behalf are engaged in accordance with local labour laws and appropriate employment standards.

 Risk assessment and key risk areas

 AE considers its primary exposure to modern slavery risk to be in the following categories:

• Hotels, venues, and event services
• Facilities management services (including cleaning, catering, and maintenance)
• Technology hardware supply chains

Regarding technology hardware, we recognise that some components may be manufactured in regions where labour protections are less robust. We therefore rely on supplier assurances and due diligence processes to understand and mitigate these risks.

In service-based categories, risks may arise through subcontracted labour or recruitment practices further down the supply chain. We therefore expect suppliers to maintain appropriate oversight of their workforce and subcontractors.

To manage and reduce risk, AE undertakes the following measures:

• Supplier onboarding checks and due diligence assessments
• Contractual controls relating to modern slavery compliance
• Supplier self-certification regarding labour practices and supply chain oversight
• Right to audit suppliers where appropriate
• Review of purchasing practices to avoid undue pressure that may increase human rights risks
• Internal escalation routes for reporting concerns

We also encourage open communication and reporting of any ethical concerns through internal reporting channels, line management, or senior leadership.

Social responsibility and human rights

AE is committed to respecting human rights and conducting business in a socially responsible manner. We aim to ensure that our operations and supply chains are not complicit in human rights abuses. We will continue to review and enhance our policies, procedures, and training to strengthen our approach to modern slavery risk management.

Effectiveness and continuous improvement

AE is committed to continuous improvement in its approach to modern slavery prevention. We will continue to develop our processes and monitor their effectiveness, including:

• strengthening supplier due diligence processes
• improving internal awareness and training
• reviewing procurement practices
• enhancing risk identification across supply chains

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and is approved by the Board of Austin Elliot Consultancy Ltd.

 

This statement covers the financial year ending 31 March 2026.

It was approved by the Board on 13 January 2026 and signed on its behalf by Ben Norton, Technical Partner.

Next review date: January 2027