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Statement of Commitment

Cyber Security Specialists Ltd (“CSS”) is committed to acting ethically, with integrity and transparency in all business dealings. We are committed to preventing modern slavery, servitude, forced labour, compulsory labour and human trafficking within our business operations and supply chain.

We recognise our responsibility to uphold and support fundamental human rights and to ensure that modern slavery is not taking place in any part of our organisation or supply chain.

This statement is made in accordance with Section 54 of the UK Modern Slavery Act 2015 and sets out the steps taken by Cyber Security Specialists Ltd during the reporting period to minimise the risk of modern slavery within our business and supply chain.

Reporting Period

This statement relates to the financial year:
1 April 2026 to 31 March 2027

Our Organisation

Cyber Security Specialists Ltd is an independent cyber security consultancy based in
Manchester, United Kingdom.

We provide:
  • Cyber Security Consultancy
  • Risk Management Services
  • Governance, Risk and Compliance Support
  • Security Testing Services
  • Managed Security Services
  • Information Security Advisory Services
Our clients include:
  • Government organisations
  • Public sector bodies
  • Medium and large enterprises
  • Small and medium-sized businesses

Our operations are primarily conducted within the United Kingdom and Europe.

Our Supply Chains

As a professional services organisation, our supply chain risk is relatively low compared to
industries such as manufacturing, agriculture or construction. However, we recognise that
modern slavery risks can still arise through suppliers and contractors.

Our supply chain includes:
  • Recruitment agencies
  • Contract personnel
  • IT hardware suppliers
  • Software vendors
  • Cloud service providers
  • Artificial Intelligence service providers;
  • Data processing service providers;
  • Managed service providers;
  • Professional service providers
  • Facilities and office service providers

We expect all suppliers, contractors and business partners to adhere to the same ethical
standards that we apply within our own business.

Policies Supporting the Prevention of Modern Slavery

CSS maintains the following policies and procedures that support our commitment to preventing modern slavery:
  • Employee Handbook – Defines expected employee behaviours and ethical standards and contains the following policies
  • Whistleblowing Policy – a confidential mechanism for employees, contractors and stakeholders to report concerns without fear of retaliation
  • Equal Opportunities Policy – Promotes fair treatment and equal opportunity throughout employment
  • Recruitment and Selection Policy – Ensures lawful recruitment practices and robust verification procedures
  • Corporate Social Responsibility (CSR) Policy – Demonstrates our commitment to ethical business practices and responsible supplier relationships
  • Supplier Management Procedures – Establish requirements for supplier selection, approval and ongoing monitoring

All policies are reviewed at least annually or sooner if legislative, contractual or organisational changes require amendment.

Risk Assessment and Risk Management

CSS applies a risk-based approach to identifying and managing modern slavery risks. The following activities are considered during risk assessments:
  • Recruitment activities
  • Use of temporary or contract labour
  • Agency workers
  • Supplier onboarding
  • Overseas suppliers
  • Geographical regions of operation
  • Labour-intensive service providers
  • Outsourced technology services
  • AI-enabled services
  • Data processing activities
  • Cloud hosting arrangements
The Company assesses risk using factors including:
  • Country of operation
  • Industry sector risk
  • Workforce type
  • Previous compliance history
  • Publicly available adverse information
  • Use of offshore labour;
  • Complex subcontracting arrangements;
  • Reliance on outsourced technology providers;
  • AI and technology supply chains; and
  • High-risk jurisdictions identified through recognised international indices.

Enhanced due diligence may be undertaken where higher risk indicators are identified.

Recruitment and Employment Controls

To minimise the risk of modern slavery within our workforce, CSS:
  • Conducts Right to Work checks for all employees and contractors
  • Verifies identity documentation before employment commences
  • Ensures individuals enter employment voluntarily
  • Maintains contracts of employment that clearly define terms and conditions
  • Pays employees at or above applicable National Minimum Wage and National Living Wage requirements
  • Operates lawful payroll practices
  • Prohibits any form of forced, bonded or involuntary labour

Any suspected concerns are immediately escalated to senior management.

Supplier and Technology Due Diligence

Prior to engaging suppliers, CSS undertakes appropriate due diligence activities where
relevant and proportionate.

This may include:
  • Assessing supplier reputation
  • Reviewing publicly available information
  • Reviewing supplier policies and certifications
  • Evaluating modern slavery, human rights and ethical labour controls
  • Reviewing Environmental, Social and Governance (ESG) commitments
  • Assessing geographical and sector-specific risks
  • Reviewing supply chain transparency
  • Assessing technology and cloud service provider risks
  • Obtaining confirmation of legal compliance where appropriate
Where significant concerns are identified, CSS reserves the right to:
  • Request corrective actions
  • Conduct further assessments
  • Suspend new work
  • Terminate supplier relationships where satisfactory improvements are not achieved
Where relevant, supplier assessments may also consider:
  • Geographic location of data centres
  • Jurisdictional and regulatory environments
  • Regional human rights considerations
  • Labour standards applicable to technology and hosting providers
  • Supply chain transparency and accountability arrangements

Artificial Intelligence and Emerging Technologies

CSS recognises that Artificial Intelligence (AI) and emerging technologies may introduce additional ethical, human rights and supply chain considerations.

Where AI-enabled products or services are utilised or procured, CSS shall seek to consider:
  • Transparency of AI service providers
  • Human oversight and accountability mechanisms
  • Compliance with applicable legal and regulatory requirements
  • Ethical use of AI technologies
  • Potential impacts on individuals and society
  • Information security and privacy controls
  • Responsible sourcing of technology services
  • Supplier governance arrangements

CSS does not knowingly engage with suppliers whose use of Artificial Intelligence is inconsistent with applicable legal, ethical or human rights obligations.

Responsibilities

Board of Directors

The Board has overall responsibility for ensuring compliance with this statement and promoting ethical business practices throughout the organisation.

Managing Director responsible for:
  • Approval of this statement
  • Oversight of modern slavery risks
  • Resource allocation
  • Escalation and investigation of significant concerns
Managers responsible for:
  • Ensuring compliance with company policies
  • Identifying and escalating concerns
  • Supporting employee awareness and training
Employees and Contractors responsible for:
  • Remaining vigilant to modern slavery indicators
  • Reporting concerns immediately
  • Complying with company policies and procedures

Training and Awareness

CSS provides awareness training to managers and relevant personnel to ensure they understand:
  • The risks of modern slavery and human trafficking
  • Risks associated with outsourced technology suppliers
  • Ethical considerations relating to technology and AI-enabled services
  • Human rights considerations within supply chains
  • Indicators of exploitation
  • Reporting mechanisms
  • Supplier-related risks
  • Escalation procedures
  • Whistleblowing arrangements

New managers must complete relevant training within one month of appointment. Additional awareness activities may be conducted periodically as part of ongoing compliance programmes.

Reporting Concerns

Employees, contractors, suppliers and other stakeholders are encouraged to report concerns regarding suspected modern slavery.

Reports may be made through:
  • Line management
  • Whistleblowing channels

All reports will be investigated appropriately and treated confidentially wherever possible.

Measuring Effectiveness

CSS monitors the effectiveness of its anti-slavery programme through the following Key Performance Indicators (KPIs):
  • 100% completion of modern slavery awareness training for relevant personnel
  • 100% completion of Right to Work checks for employees and contractors
  • Completion of supplier due diligence reviews where applicable
  • Number of modern slavery concerns raised and investigated
  • Annual review of policies and procedures
  • Annual review of higher-risk suppliers, cloud providers and technology providers

The results of these measures are reviewed as part of management oversight activities.

Continuous Improvement

CSS is committed to continually improving its approach to identifying, preventing and mitigating modern slavery risks.

The company will:
  • Review this statement annually
  • Monitor legislative and regulatory developments
  • Assess supplier, technology and AI-related risks
  • Improve employee awareness
  • Strengthen due diligence processes where necessary
  • Review emerging risks associated with technology supply chains and outsourced services

Approval

This Modern Slavery and Human Trafficking Statement has been reviewed and approved by the Board of Directors of Cyber Security Specialists Ltd.

Signed:
Ben Pollard
Managing Director
Cyber Security Specialists Ltd
Date: 07 September 2026