Modern Slavery Policy

Modern Slavery and Human Trafficking Policy Statement 2025 Introduction It continues to be a priority for Createc Ltd to have a zero-tolerance approach to any form of modern slavery or human trafficking. This extends to all aspects of our business and supply chain. Modern slavery is a crime and violation of fundamental human rights. It…

Modern Slavery and Human Trafficking Policy Statement 2025

Introduction

It continues to be a priority for Createc Ltd to have a zero-tolerance approach to any form of modern slavery or human trafficking. This extends to all aspects of our business and supply chain.

Modern slavery is a crime and violation of fundamental human rights. It encompasses slavery, servitude, human trafficking and forced labour, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Organisation and Business

Createc’s business culture is based on the following statement, developed by the company, which forms the basis an ethical vision of Createc’s working culture:

“Createc is a company where applied R&D is the primary activity. Our mission is to create wealth for our customers and for ourselves by using emerging technology to achieve more using fewer resources. We lead the technology generation process: we don’t wait for others to show us the way; we treat received wisdom with suspicion; but we also listen to our customers and put their needs ahead of our own desires.

We succeed when something we made goes out into the real world and makes it better. Createc will achieve this by balancing technology ‘push’ and commercial ‘pull’; neither can make things happen by itself. We aspire to build his balance into everything we do; to make it a marriage not a tug-of-war.

Createc believes that applied R&D is the best investment of all. We will continually re-invest a proportion of our profits into both capability enhancing fundamental R&D and into commercialisation activities; this way we can achieve sustainable long-term growth in capability, opportunity, reputation, resources and wealth.

Createc acknowledges that investment in R&D is an investment in people; we want our people to continuously develop and grow in capability. We expect each other to actively seek challenges, to be not only willing but eager to work at and sometimes beyond our limit of comfort. We expect to be rewarded for our efforts and for our achievements.

When we are successful we instinctively want to reinvest some of that success in others. There is no absolute limit on what Createc can one day achieve: our customer is the human race; our market is the future”

We believe that this philosophy which underpins the way in which we run our business is directly relevant to achieving a mutually beneficial relationship with our customers and wider stakeholders in society.

We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted. Our policies and procedures relating to the Modern Slavery Act are in line with our culture and values.

Responsibility for the Policy

The board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The compliance team have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery however ultimate responsibility for the implementation and compliance with this policy firmly remains with the CEO and board of Directors.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

Supply Chain

Createc is committed to ensuring transparency in our business and our approach to tackling modern slavery throughout our supply chains.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against modern slavery and human trafficking, and we expect that our suppliers will hold their suppliers to the same high standards.

Anyone working on behalf of Createc in any capacity, including employees at all levels, Directors, agency workers, seconded workers, volunteers, interns, contractors, external consultants, third-party representatives and business partners is held to the same high standard.

All goods and services procured go through a central team, which is responsible for assessing the suitability and any associated risk of suppliers and ensuring the relevant due diligence checks are conducted.

Preferred suppliers are also highlighted on a purchasing platform, and the procurement team is responsible for maintaining awareness of preferred supplier relationships across the business.

Our Policies and Procedures in Relation to Modern Slavery

We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or business.

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner and to show our commitment to acting with integrity in all our business relationships. These include, but are not limited to:

  • Our Code of Conduct (Disciplinary and Capability Procedure)
  • Our Whistleblowing Policy
  • Our Diversity, Equality and Inclusion (DEI) Policy
  • Our Purchasing Procedure
  • Our Createc Recruitment Procedure

To ensure a high level of understanding, a review of policies forms a mandatory part of the onboarding process for all new starters.

All employees identified as potentially having direct communications with third party suppliers will be requested to complete the iHasco modern slavery training module.

The training module is available to all employees, at their request.

In addition to the above, we provide regular and relevant CFSI training to our employees on the issue of modern slavery and human trafficking and how to identify, prevent, tackle and report it.

Createc has examined the risk of modern slavery within its business operations on a risk-based approach and considers the risks of modern slavery in its supply chain to be low.

The assessment is based upon the nature of our business and the services we provide to customers which present very limited exposure to modern slavery risks.

Compliance with this Policy

Employees must ensure they read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.

Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees must therefore notify their manager, compliance team or the CEO as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.

Employees should raise concerns at the earliest possible stage. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the compliance manager.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form, is or may be taking place in any part of our own business or in any of our supply chains.

Our Performance Indicators

We measure how effective we have been in ensuring that modern slavery and human trafficking is not taking place in our business or supply chain by using the following key performance indicators:

  • The number of reports received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
  • The number of suppliers audited or assessed for compliance with our standards and expectations.
  • The number of suppliers that have been terminated or remediated as a result of non-compliance or violations.
  • The level of engagement and feedback from our suppliers on our anti-slavery initiatives and expectations.
  • The level of awareness and understanding of our employees and business partners on the issue of modern slavery and human trafficking and how to prevent it.

Communication, Awareness and Training

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Our Commitment

We are committed to reviewing and enhancing our policies and procedures on an ongoing basis, to ensure that we are effectively preventing and combating modern slavery and human trafficking in our business and supply chain.

To ensure ethical conduct throughout our operations, we will continue to cultivate strong relationships with our external suppliers and partners.

We will actively engage with them on matters concerning modern slavery and human trafficking, to ensure their ethical practices and values consistently align with Createc’s.

This policy statement will be reviewed and updated yearly and published on our website in accordance with the requirements of the Modern Slavery Act 2015.

Approval

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year 2025/2026. Createc’s financial year ends on 31 October.

For and on behalf of Createc:

Will Newsom
CEO
26th August 2026