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MODERN SLAVERY STATEMENT

This statement is published voluntarily by Soteria International Group Ltd (trading as Soteria Consulting) to demonstrate our commitment to preventing modern slavery and human trafficking in our operations and supply chains. Whilst we are not currently classified as a 'relevant commercial organisation' under Section 54 of the Modern Slavery Act 2015 (our annual turnover does not exceed the £36 million threshold), we recognise the importance of ethical business practices and transparency in addressing modern slavery risks.

This statement sets out the steps we have taken and continue to take to ensure that slavery and human trafficking are not occurring in our business or supply chains.

1. Our Organisation, Business and Supply Chains

Organisational Structure

Soteria International Group Ltd is a UK-registered transformation consultancy based in the United Kingdom. We operate as a limited company under the trading name Soteria Consulting.

Our Business

Soteria Consulting provides specialist transformation consultancy services across the following areas:

  • People-first operating models and organisational design

  • Diversity, Equality, Inclusion and Belonging (DEIB) diagnostics and strategy

  • AI-enabled culture analytics and people intelligence

  • Public sector transformation and service design

  • Digital product development and SaaS solutions

We primarily serve UK public sector bodies, charities, not-for-profit organisations, and small to medium-sized enterprises (SMEs).

Our Supply Chains

As a knowledge-based consultancy, our supply chains are limited in scope and primarily comprise:

  • IT services and software subscriptions (predominantly UK and EU-based providers)

  • Professional services (legal, accounting, compliance, and specialist sub-contractors)

  • Office equipment and supplies

  • Training and development providers

2. Our Policies in Relation to Slavery and Human Trafficking

Soteria Consulting maintains a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships.

Our commitment is embedded in the following policies and practices:

  • Code of Conduct: Sets out our expectations for ethical behaviour from all employees, associates, and contractors, including respect for human rights and fair working conditions.

  • Recruitment and Employment Practices: We ensure all employment is freely chosen, verify right to work documentation, and comply with UK employment law, including the National Minimum Wage and working time regulations.

  • Supplier Standards: We expect our suppliers and contractors to uphold equivalent standards and to operate in accordance with applicable laws, including those relating to modern slavery.

  • Whistleblowing: We encourage the reporting of concerns about unethical conduct or suspected modern slavery without fear of retaliation.

3. Due Diligence Processes

We undertake the following due diligence activities to identify and mitigate modern slavery risks:

Supplier Assessment

  • Conducting proportionate risk assessments of new suppliers based on sector, geography, and service type

  • Requesting evidence of compliance with modern slavery legislation from higher-risk suppliers

  • Reviewing supplier terms and conditions to include modern slavery compliance obligations

Employment and Contracting

  • Verifying identity and right to work for all employees and contractors

  • Ensuring transparent and fair payment practices, including adherence to National Minimum Wage requirements

  • Conducting periodic reviews of contractor and associate relationships

Ongoing Monitoring

  • Reviewing supplier performance and conduct on an ongoing basis

  • Investigating and addressing any concerns or red flags raised internally or by third parties

4. Risk Assessment and Management

Lower-Risk Areas

  • Professional Services: Our primary suppliers are UK-based professional service providers (legal, accounting, IT) operating under robust regulatory frameworks.

  • Direct Employment: We directly employ or contract with all personnel, maintaining full visibility over working conditions and remuneration.

Areas Requiring Ongoing Vigilance

  • IT Hardware and Equipment: We recognise that technology supply chains may involve manufacturing in regions with higher modern slavery risks. We prioritise procurement from reputable suppliers with transparent supply chain policies.

  • Specialist Sub-Contractors: When engaging specialist contractors, we conduct appropriate due diligence to ensure compliance with labour standards.

Steps Taken to Assess and Manage Risk

  • Prioritising suppliers with published Modern Slavery Statements or equivalent policies

  • Including modern slavery compliance clauses in supplier contracts

  • Maintaining an approved supplier list based on risk assessment criteria

  • Reviewing and updating our risk assessment annually

5. Measuring Effectiveness

We assess the effectiveness of our approach through the following performance indicators:

  • Supplier Compliance: Percentage of suppliers assessed for modern slavery risk and confirmed as compliant (target: 100% of new suppliers).

  • Employment Practices: 100% verification of right to work documentation for all employees and contractors.

  • Incident Reporting: Number of modern slavery concerns reported and investigated (target: zero confirmed incidents; all reports investigated promptly).

  • Training Completion: Percentage of relevant staff completing modern slavery awareness training (target: 100% annually).

  • Policy Review: Annual review and update of this statement and related policies.

We commit to continuous improvement in our approach and will enhance our monitoring and reporting mechanisms as our business grows.

6. Training and Capacity Building

We ensure that relevant personnel have appropriate knowledge and understanding of modern slavery risks through:

  • Awareness Training: All employees and associates receive induction training on our Code of Conduct, which includes modern slavery awareness.

  • Procurement and Supply Chain: Personnel involved in procurement and supplier management receive specific guidance on identifying modern slavery risks and conducting appropriate due diligence.

  • Regular Updates: Annual refresher training is provided to ensure continued awareness and compliance with evolving best practices.

  • External Resources: We make use of publicly available guidance from the Home Office, Stronger Together, and other recognised bodies to inform our training materials.

7. Commitment to Continuous Improvement

We recognise that addressing modern slavery is an ongoing responsibility. As our business evolves, we will:

  • Review and enhance our due diligence processes annually

  • Expand our supplier engagement and monitoring activities as our supply chain grows

  • Strengthen our training and awareness programmes

  • Publish updated statements annually to reflect our progress and learnings

Approval and Publication

This statement has been approved by the Managing Director of Soteria International Group Ltd and represents our commitment to preventing modern slavery in all its forms.

Beulah Iriele

Founder and Managing Consultant

Soteria International Group Ltd

Date: March 2026

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