Modern Slavery Policy

Modern Slavery Policy Statement

Last Reviewed : 03/01/2025

Next Review Date : 03/01/2028

Highway Data Systems Limited is committed to conducting its business ethically, transparently and with integrity. We support the principles of the Modern Slavery Act 2015 and operate a zero-tolerance approach to modern slavery, servitude, forced or compulsory labour and human trafficking.

What Modern Slavery Means

Modern slavery includes slavery, servitude, human trafficking, child labour and forced or compulsory labour. Highway Data Systems Limited is committed to ensuring that these practices do not take place within our own business or, where reasonably practicable, within our supply chain.

Our Commitments

To help prevent modern slavery, Highway Data Systems Limited:

• Ensures all employees are eligible to work in the UK and are paid in accordance with applicable wage legislation.

• Operates fair employment, payroll and working practices.

• Does not use subcontractors for its core activities.

• Sources goods and services from reputable suppliers, the majority of which are established businesses such as major online retailers, cloud service providers, software providers and recognised equipment/component suppliers.

• Takes a proportionate, risk-based approach to supplier engagement due to the size and low-risk nature of the business.

• Would not knowingly work with any supplier or third party involved in modern slavery, exploitation or unethical labour practices.

• Provides a reporting route so employees can raise concerns about unethical or illegal practices without fear of unfair treatment.

Supplier Engagement and Supply Chain Risk

• HDS is a small business and does not meet the statutory threshold for publishing a Modern Slavery Statement. However, we remain committed to acting ethically and responsibly and to preventing modern slavery, servitude, forced or compulsory labour and human trafficking within our own business and supply chain.

• HDS does not use subcontractors for its core activities. Our supply chain is limited and is considered low risk, consisting mainly of established and reputable suppliers such as major online retailers, cloud service providers, software subscription providers, equipment/component suppliers and general consumable suppliers.

• Due to the nature and scale of our operations, HDS does not currently carry out formal modern slavery audits or supplier certification checks. However, we take a proportionate, risk-based approach and would not knowingly engage with any supplier or third party where there were concerns regarding modern slavery, exploitation or unethical labour practices.

• If HDS identifies a higher-risk supplier, service, location or activity in the future, we will carry out appropriate checks before engagement and take action where necessary. Any concerns relating to modern slavery or unethical labour practices must be reported to the Director.

Reporting Concerns

Employees are encouraged to raise any concerns relating to modern slavery, forced labour, unethical labour practices or exploitation as soon as possible.

Concerns should be reported directly to the company Director and will be treated seriously and handled confidentially where possible. HDS will investigate any concerns promptly and take appropriate action where required.

Where concerns relate to a supplier or third party, HDS would review the relationship and would not knowingly continue to work with any organisation involved in modern slavery, exploitation or unethical labour practices.

Employees will not be penalised or treated unfairly for raising a genuine concern in good faith.

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