Supplier onboarding checks
Appropriate to the nature of the relationship (including supplier questionnaires and confirmation of alignment to our Supplier Code of Conduct)
Modern Slavery Statement
Creating with integrity
Building with responsibility
We design technology with care, accountability, and respect for everyone in our supply chain
Modern Slavery, Child Labour and Human Trafficking Statement 2025
Dataframe Solutions Ltd
Financial year: 1 July 2024 – 30 June 2025
Published: December 2025
Approved by: Board of Directors, Dataframe Solutions Ltd
1. Statement of commitment
This statement sets out Dataframe Solutions Ltd’s commitment to preventing modern slavery, child labour and human trafficking across our business and supply chain. It outlines the principles, policies, and practical steps we take to identify, assess, and reduce the risk of exploitation, and the governance in place to support transparency, accountability and continuous improvement.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and reflects the UK Government’s updated guidance on the content and quality of modern slavery statements, including clearer expectations on action, governance, and effectiveness.
This statement outlines our approach, actions, embedded risk management processes, and continuous improvement measures for the financial year ending 30 June 2025, in line with the expectations set out in the UK Government’s updated modern slavery guidance issued in 2025. We publish this statement on our website and recognise the UK Government’s Modern Slavery Statement Registry as an important transparency mechanism.
2. About Dataframe Solutions Ltd
Dataframe Solutions Ltd is a UK‑headquartered data and analytics consultancy dedicated to building solutions organisations can trust. We bring together thoughtful, collaborative problem‑solvers who work openly and responsibly to tackle complex challenges and deliver meaningful outcomes.
Our purpose is to help clients make confident, data‑informed decisions through the clear, transparent, and well‑governed use of technology. Guided by integrity and accountability, we take responsibility for how data is sourced, designed, and delivered ensuring everything we create is ethical, explainable, and built for long‑term impact.
We provide data analytics consulting, cloud engineering, managed services, and productised data solutions to private‑sector organisations across industries including financial services, retail and e‑commerce, telecommunications, health and life sciences, and technology. Our operating model is primarily based on professional services, supported by software‑enabled solutions and trusted technology partnerships.
3. Governance and accountability
Our Board of Directors has ultimate responsibility for this statement and for oversight of our approach to ethical practice and responsible sourcing. Executive responsibility sits with senior leadership, supported by operational leads across delivery, people, and supplier management.
We review our approach at least annually, with continuous improvement informed by operational experience, supplier feedback, and evolving guidance and best practice
4. Our policies and standards
We maintain a zero‑tolerance approach to modern slavery, child labour and human trafficking. Our policies and standards support ethical practice across our operations and suppliers, and include:
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Anti‑Slavery and Human Trafficking Policy
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Supplier Code of Conduct
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Whistleblowing Policy
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Ethical Recruitment and Right‑to‑Work processes
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Supplier and Subcontractor Onboarding and Management controls
These policies are designed to embed responsible behaviour in day‑to‑day decision‑making and to ensure concerns can be raised and acted upon promptly
5. Our supply chain and responsible sourcing
Our supply chain reflects our commitment to responsible sourcing, ethical partnerships, and transparent operations. We recognise the importance of understanding our business structure, operating model, and supply chain in order to identify, assess, and manage ethical and modern slavery risks effectively, an approach consistent with UK Government expectations for modern slavery statements.
Our supply chain includes:
Technology platforms and SaaS providers
Including cloud infrastructure, data platforms, developer tools, and supporting software used to design, build, deploy, and operate our solutions. We select providers using a risk‑based approach that considers governance, transparency, and the supplier’s commitment to responsible business practices, and we maintain oversight through contractual controls and periodic review
Specialist subcontractors and independent consultants
Engaged on an onshore basis at present to support close collaboration, direct oversight, and strong working relationships with every person on our delivery teams. This approach supports meaningful engagement with each team member and strengthens our ability to uphold consistent standards across delivery
Software licensing and marketplace partners
Including suppliers of commercial software, subscriptions, and related services. We manage these relationships through standard contracting, supplier onboarding checks, and ongoing review to ensure partners align with our ethical expectations and do not introduce unmanaged third‑party dependencies
Hardware and peripherals
Including end‑user devices and accessories procured via authorised resellers. Where relevant, we consider upstream supply‑chain complexity and use proportionate checks, supplier assurances, and reputable sourcing routes to reduce exposure to labour exploitation risks commonly associated with multi‑tier manufacturing supply chains.
Corporate and operational services
Including recruitment, training, professional services, facilities support, and travel. For labour‑sourcing activities (such as recruitment), we apply enhanced due diligence to reduce the risk of unethical recruitment practices, including confirmation of lawful working arrangements and expectations regarding fair treatment and worker protections
6. Risk management and due diligence
Because modern slavery risks can exist in any sector, we apply proportionate due diligence and ongoing oversight across our operations and supply chain. In line with updated UK guidance, our approach focuses on meaningful action, practical controls, and continuous improvement.
Our due diligence and risk controls include:
Contractual standards
Including ethical compliance obligations and rights to address non‑compliance, including termination where necessary
Baseline Personnel Security Standard (BPSS)
All employees and contractors are BPSS‑checked as a minimum, including identity verification, right‑to‑work checks, and confirmation that no worker pays unlawful recruitment fees or has identity documents retained.
Clear reporting and escalation mechanisms
Enabling employees, contractors, and suppliers to raise concerns confidentially, with defined processes for investigation, remediation, and governance oversight
Recruitment safeguards
All employees and contractors are BPSS‑checked as a minimum, including right‑to‑work verification and protections against unlawful recruitment practices
Ongoing supplier management
Including periodic reviews and targeted follow‑ups where a relationship involves labour‑intensive delivery models, multi‑tier supply chains, or other elevated risk indicators
Where we identify a potential risk or concern, we prioritise responsible remediation and work with relevant parties to address root causes
7. Training and awareness
We provide mandatory online training for employees and relevant contractors through a course appraised by The CPD Certification Service, which provides independent Continuing Professional Development (CPD) accreditation compatible with international requirements.
The training is designed to raise awareness, build understanding, and support practical risk mitigation. It covers:
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What modern slavery is and how it manifests;
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The scale and extent of modern slavery globally;
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The impacts and risks associated with modern slavery in business and supply chains;
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Legal and regulatory reporting requirements;
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Risk mitigation and prevention measures;
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Indicators and warning signs of modern slavery; and
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Appropriate signposts, reporting routes, and external resources.
Training completion is monitored and reviewed as part of our ongoing approach to embedding awareness and strengthening our ability to identify and respond to potential risks across our operations and supply chain.
8. Reporting, concerns and remediation
We encourage employees, contractors, and suppliers to raise concerns without fear of retaliation. Reports can be made through management channels or via our confidential whistleblowing process.
If a modern slavery concern is identified, we will:
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Assess the issue promptly and safely, prioritising the welfare of potentially impacted individuals;
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Require appropriate corrective action and remediation;
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Suspend or terminate supplier relationships where necessary; and
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Report to relevant authorities where appropriate and lawful.
9. Measuring effectiveness
We recognise the importance of monitoring progress and strengthening transparency over time. We track effectiveness using practical indicators such as:
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Completion of training by employees and relevant contractors;
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Onboarding coverage for in‑scope suppliers (e.g., acceptance of our Supplier Code of Conduct);
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Proportion of contracts including appropriate ethical compliance expectations;
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Number of concerns raised and outcomes achieved; and
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Evidence of improvement actions completed where issues are identified.
The refreshed UK guidance places greater emphasis on demonstrating action and effectiveness rather than relying on statements of intent alone.
10. Continuous improvement
Over the next reporting period, we will continue to strengthen our approach by:
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Enhancing supplier segmentation and review, focusing on labour‑intensive or multi‑tier supply arrangements where risk can be higher;
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Improving documentation and evidence capture to support audit readiness and transparency;
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Refreshing training and internal guidance as best practice evolves; and
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Maintaining clear governance oversight and annual review of this statement.