Modern Slavery and Human Trafficking Statement

Financial Year Ending: 31 December 2024

1. Introduction & Purpose

At Sepivi, we take seriously our ethical responsibilities. This statement is made in accordance with section 54 of the UK Modern Slavery Act 2015. It sets out the steps we have taken, and will continue to take, to ensure that modern slavery, human trafficking, forced labour, or other exploitative practices are not taking place in our business or supply chains.

We expect high standards of integrity, fairness, and accountability from all those we work with, and we are committed to ensuring that such practices have no place in our organisation or our partnerships.

2. Our Structure, Business & Supply Chains

• About us: Sepivi Limited is registered in England & Wales (No: 15356173), with registered office at 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ.
• Business activities: We deliver services in consultancy, security/privacy advisory, training, managed services, and technology support.
• Supply chain: To support our operations and deliver services, we rely on external suppliers and partners such as IT/cloud providers, professional services, training content providers, facilities & office services, and software vendors. Our supply chain is both local (UK) and international, with tiers of subcontractors in technology, infrastructure, and service delivery.

3. Risks of Modern Slavery in Our Operations & Supply Chain

We recognise that risks may arise especially where:

• Suppliers are located in regions with weaker labour laws or oversight.
• Labour subcontracting is common (e.g. IT support, data centres, hardware).
• There is low visibility beyond tier-1 suppliers (i.e. subcontractors to subcontractors).
• Suppliers are engaging in logistical or facilities management services, which historically carry labour risks.

While our operations themselves are low labour-risk (we are a service and consultancy business), we must examine and mitigate risks in our supply chain, especially in technology, facilities, and service subcontracting.

4. Policies & Standards of Conduct

To help prevent modern slavery, Sepivi has these policies and practices:

• Code of Conduct / Ethics: All employees and contractors are bound to comply with our Code, which includes a prohibition on forced labour, human trafficking, and related abuses.
• Supplier Code of Conduct / Procurement Policy: Our standard contracts require suppliers to comply with anti-slavery standards, allow audits or reviews, and require adherence to labour and human rights laws.
• Whistleblowing & incident reporting: We provide confidential channels for raising concerns. Any allegation of modern slavery or exploitation will be investigated, and remedial action taken.
• Due diligence: During onboarding and periodic reviews, we assess supplier risk, require documentation of labour rights compliance, and may exclude suppliers failing to meet standards.
• Training & Awareness: We plan to provide training for staff in procurement, operations, and management to recognise red flags of modern slavery and how to respond.

5. Due Diligence and Assessment

We apply a risk-based approach to due diligence across our supply chain:

• Supplier screening: Before contracting suppliers, especially in higher-risk jurisdictions, we request suppliers to disclose labour practices, their modern slavery policies, and provide references or third-party audits.
• Ongoing reviews: Based on size or strategic importance, suppliers may be subject to regular assessments — questionnaires, site visits, or audits.
• Contractual audit rights: Where possible, we contractually reserve rights to audit or inspect supplier compliance with anti-slavery obligations.
• Remedial action: If a supplier is found to be noncompliant, we require mitigation or corrective plans, and may terminate the relationship in serious cases.

6. Monitoring, Effectiveness & Key Performance Indicators

We aim for continuous improvement. To measure our progress, we will monitor:

• Number of supplier assessments conducted;
• Percentage of suppliers who confirm compliance or improve under review;
• Number of red-flag incidents raised, investigated, and resolved;
• Staff training completion rates;
• Changes made to contracts or policies based on identified risk.

This statement will be reviewed annually by senior management to ensure it remains up to date and effective.

7. Future Commitments

Over the coming year, Sepivi aims to:

• Expand our supplier due diligence to include deeper tiers of subcontractors;
• Increase training coverage especially for procurement, operations, and leadership;
• Strengthen contract clauses and audit rights;
• Enhance our supplier portal to gather regular compliance declarations and documentation;
• Collaborate with partners and peers to share best practices and align on anti-slavery efforts.

8. Approval

This statement was approved by the Board of Directors of Sepivi Limited and will be reviewed and updated annually. It is published on our website in accordance with section 54(1) of the Modern Slavery Act 2015.

Lisa Robson, Director, Sepivi Limited

Date: 5th January 2025