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Modern Slavery & Human Trafficking Statement 

Introduction 

This Modern Slavery and Human Trafficking Statement relates to actions and activities for the financial year ending 31 May 2026. 

 

The statement sets down Sequora’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small.  Staff are expected to report their concerns, and management to act upon them.  

Organisational structure and supply chains 

This statement covers the business activities of Sequora which are as follows:  

 

A professional services and capability-building company that helps public and private sector organisations strengthen their commercial and procurement capability. Our business is structured around our Guardian service, which provides specialist commercial, contracting and risk-management expertise to safeguard value and ensure compliant, ethical supply-chain practice; and our Academy, which builds sustainable internal client capability through managed learning pathways that recruit, train and develop values-aligned talent. Sequora operates primarily within the United Kingdom and works with a small network of professional partners and accredited training and technology providers to deliver its services. Our supply chain is limited and low-risk, consisting mainly of UK-based professional, digital and educational service suppliers. We maintain oversight of all partners and subcontractors to ensure they meet our ethical, social-value, and labour-standards expectations, including compliance with the Modern Slavery Act 2015. 

 

The Company currently operates in the UK. Currently, our business activities and supply chain have no high-risk areas for modern slavery. 

 

Responsibility for the Company’s anti-slavery initiatives is as follows: 

  • Policies: our HR Manager and Legal Advisor are responsible for creating and reviewing policies. The process by which policies are developed is to look at best practice, ethics and compliance, and taking action to implement them. 

  • Our HR Manager and staff who handle supplier pre-boarding are responsible for due diligence in relation to modern slavery and human trafficking. 

  • Internal training: our HR Manager is responsible for ensuring that all staff undertake the compulsory courses about modern slavery and human trafficking and are aware of our relevant policies. 

  • Compliance with labour law: our HR Manager is responsible for ensuring that the Company always treats its staff ethically and in accordance with relevant labour laws. 

Training 

To ensure a good understanding of the risks of modern slavery and human trafficking in our business activities and supply chains, the Company requires all staff to complete a training course on Modern Slavery and Trafficking, during onboarding and periodically.  

Policies 

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships. 

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations: 

  • Whistleblowing policy: the Company encourages all its employees to report any concerns related to its activities or its supply chains.  

  • Code of Conduct: the Company’s Code of Conduct makes it clear that modern slavery will not be tolerated and reinforces that any concerns must be reported. 

Due Diligence Processes for Slavery and Human Trafficking 

The Company undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. The Company’s due diligence process includes evaluating the ethical risks of each new supplier, making clear our expectations of business partners and invoking sanctions against suppliers that fail to meet our ethical standards, including the termination of the business relationship. 

Performance indicators 

The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including: 

  • Colleague training completion: the percentage of employees and contractors completing Modern Slavery and Human Trafficking training during onboarding and at least every two (2) years thereafter. 

  • Incident reporting and response: number of concerns raised and the percentage resolved within appropriate timeframes. 

  • Supplier due diligence completion: the percentage of active suppliers that have undergone ethical due diligence before onboarding or contract renewal. 

 

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. Matthew Bradley (CEO) endorses this policy statement and is fully committed to its implementation. 

Last updated: 09/01/2026 

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