Our Modern Slavery Policy

Intellecta Modern Slavery Policy

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Last Updated: Tuesday, 9th September 2025
Reporting Period: Financial Year ending 31st March 2025

Intellecta Ltd is committed to acting ethically and with integrity in all our business dealings and relationships. We maintain a zero-tolerance approach to modern slavery and human trafficking within our operations and supply chains. We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains, in compliance with the Modern Slavery Act 2015.

1. About This Policy

This policy outlines the steps Intellecta Ltd has taken and continues to take to prevent modern slavery and human trafficking. It applies to all persons working for us or on our behalf in any capacity, including employees, directors, officers, agency workers, contracted staff, volunteers, agents, contractors, external consultants, third-party representatives, and business partners (collectively referred to as “associated persons”).

Modern slavery encompasses slavery, servitude, forced and compulsory labour, and human trafficking. These crimes deprive a person of their liberty and exploit them for another person’s gain. We are fully committed to respecting human rights and ensuring the fair treatment of all individuals.

2. Our Business and Supply Chains

Intellecta Ltd is a leader in AI and data science, providing advanced technological solutions to a diverse client base across various industries. Our services include data analytics, machine learning development, strategic AI consulting and web development

Our supply chains primarily involve the procurement of IT hardware and software, cloud computing services, professional services, office supplies and marketing services. While our supply chain risk is generally considered low given the nature of our industry (high-tech, professional services), we remain vigilant and committed to ethical sourcing.

3. Our Policies and Controls

To combat modern slavery and human trafficking, Intellecta Ltd has implemented and maintains the following policies and controls:

• Whistleblowing Policy: We encourage all employees and associated persons to report any concerns related to modern slavery or other unethical practices without fear of retaliation. Our whistleblowing policy provides a safe and confidential mechanism for reporting.
• Ethical Conduct Policy/Code of Conduct: This policy sets out the ethical standards expected of all employees and associated persons, including adherence to human rights principles.
• Recruitment Policy: We operate robust recruitment procedures, including verifying the identity and right to work for all employees, to ensure all employment is voluntary and legitimate.
• Supplier Code of Conduct: We expect our suppliers to adhere to high ethical standards, including compliance with all relevant anti-slavery and human trafficking laws. This is often incorporated into our contractual agreements.
• Due Diligence: For higher-risk suppliers, particularly those operating in jurisdictions with known modern slavery risks, we conduct enhanced due diligence, which may include questionnaires or direct engagement.

4. Risk Assessment and Management

We assess the risk of modern slavery and human trafficking in our business and supply chains by:

• Considering the geographical locations and industries of our suppliers.
• Evaluating the types of services and products procured.
• Monitoring relevant legislative and regulatory changes.

While we consider our direct exposure to high-risk areas for modern slavery to be low, we are committed to continuous monitoring and improvement of our risk management processes.

5. Training and Awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant employees, particularly those involved in procurement and human resources. All employees are made aware of this policy and their role in upholding it.

6. Reporting and Accountability

All employees and associated persons are encouraged to report any suspicions of modern slavery or human trafficking directly to senior Intellecta management or through our confidential whistleblowing address at concerns@intellecta.co.uk. All reports will be investigated promptly and confidentially.

We are committed to taking appropriate action against any individual or organisation found to be involved in modern slavery or human trafficking, which may include disciplinary action, contract termination, or reporting to relevant authorities.

7. Policy Review

This Modern Slavery and Human Trafficking Policy will be reviewed annually and updated as necessary to reflect changes in legislation, best practice, and our business operations. The Board of Directors holds overall responsibility for ensuring this policy complies with our legal and ethical obligations.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Intellecta Ltd’s slavery and human trafficking statement for the current financial year.

Mr Tom Simpson & Ms. Lucy Roberts,
Directors, Intellecta Ltd.
Tuesday, 9th September 2025