KEYSIGMA MODERN SLVERY AND HUMAN TRAFFICKING STATEMENT
For the financial year 1 April 2026 to 31 March 2027
KEYSIGMA is committed to conducting business ethically and taking proportionate steps to prevent modern slavery and human trafficking in our operations and supply chains.
1. Purpose and commitment
This is KEYSIGMA’s first voluntary modern slavery and human trafficking statement.
KEYSIGMA does not currently meet the £36 million annual turnover threshold at which publication of a modern slavery statement is required under section 54 of the Modern Slavery Act 2015. We have nevertheless chosen to publish this statement voluntarily to demonstrate our commitment to ethical and responsible business practices and to support the expectations of our customers and partners, including those operating within government and defence supply chains.
We have zero tolerance for slavery, servitude, forced or compulsory labour, human trafficking, child labour, debt bondage or any other form of severe labour exploitation. We expect equivalent standards of conduct from our employees, contractors, suppliers and business partners.
2. Our organisation and supply chains
KEYSIGMA is a specialist cyber security consultancy and certification body based in Cheltenham. Our services are delivered mainly by a small team of directly employed, skilled professionals, supported where necessary by selected consultants, subcontractors and partner organisations.
Our principal suppliers provide cloud and software services, communications, computers and other electronics, professional services, recruitment and screening, training, office facilities and general business support. Many direct suppliers are UK based, although technology and hardware supply chains may be global and our visibility below the first tier is limited.
3. Policies, responsibility and employment practices
The Managing Director has overall responsibility for modern slavery risk and approval of this statement. The Operations Lead is responsible for day-to-day implementation, maintaining relevant supplier assurance records, supporting staff awareness and escalating material concerns.
Our approach is supported by relevant internal policies and procedures, including our recruitment and onboarding arrangements, Whistleblowing Policy, Grievance Procedure, Equality and Diversity provisions, employee conduct requirements and supplier management processes.
Our recruitment and onboarding processes include identity and right-to-work checks, written employment terms and proportionate pre-employment screening. Employees are paid directly by KEYSIGMA. We do not charge workers recruitment fees, require deposits as a condition of employment or retain original identity documents.
Employees are free to leave their employment subject to the notice provisions in their contracts, and we expect equivalent standards from relevant contractors and suppliers.
4. Risk assessment and supplier due diligence
We consider the risk of modern slavery within our directly employed professional workforce to be low. The areas of greater potential exposure are electronics and hardware manufacturing, outsourced facilities and support services, subcontracted labour and complex international technology supply chains.
We take a proportionate, risk-based approach to suppliers. During 2026/27 we will formalise our supplier review process, starting with business-critical and higher-risk suppliers. Depending on the risk, this may include reviewing a supplier’s modern slavery statement or policy, requesting compliance assurances, considering its location and use of subcontractors, and including appropriate modern slavery requirements in supplier terms.
Suppliers are expected to comply with applicable employment and human rights laws, ensure work is freely chosen, prohibit forced and child labour, avoid worker-paid recruitment fees and apply equivalent standards to relevant subcontractors. Where required by a customer or contract, we will co-operate with reasonable supply chain mapping, assurance and audit requests.
5. Reporting, training and responding to concerns
Employees, contractors and suppliers are encouraged to report any concerns relating to modern slavery or human trafficking to the Operations Lead or the Managing Director.
Concerns will be treated sensitively and, so far as reasonably practicable, confidentially. Nobody raising a concern in good faith will be subjected to retaliation or detrimental treatment as a result of doing so.
Where a credible concern is identified, we will investigate promptly and take proportionate action, with the safety and welfare of affected or potentially affected individuals prioritised. Where appropriate, this may include working with suppliers, customers, specialist organisations and relevant authorities to support remediation and corrective action.
Termination of a supplier or business relationship will be considered where there is serious misconduct, continued exploitation, deliberate concealment or a refusal to take appropriate corrective action.
During 2026/27, staff will receive proportionate awareness training covering the signs of modern slavery, higher-risk supply chains and how to report a concern. Staff involved in recruitment, supplier management and contract delivery will receive additional guidance relevant to their responsibilities.
6. Our commitments for 2026/27
During 2026/27 we will:
• map and risk-rate our direct suppliers, prioritising critical and higher-risk categories
• introduce proportionate supplier checks and contractual wording where appropriate
• provide modern slavery awareness training to all staff
• record concerns, actions and outcomes and review this statement annually
Progress against these commitments will be considered as part of our annual review of this statement, taking account of KEYSIGMA’s size, activities and supply-chain risk.
7. Approval
This statement has been prepared for the financial year 1 April 2026 to 31 March 2027. It will be reviewed annually and published on the KEYSIGMA website following approval by the Managing Director.