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MODERN SLAVERY & HUMAN TRAFFICKING POLICY

Last updated: 13/01/26

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1. Purpose of this Policy

WHO2 Global Ltd (“WHO2”, “the Company”) is committed to preventing modern slavery and human trafficking within its operations and supply chains. This policy outlines WHO2’s approach to identifying, reporting and preventing exploitation, ensuring compliance with:

  • UK Modern Slavery Act 2015

  • International Labour Organisation (ILO) standards

  • Global human rights and ethical business expectations

  • Supplier governance requirements of WHO2 partners

The Company adopts a zero-tolerance approach to slavery, servitude, forced labour, child labour and human trafficking.

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2. Scope

This policy applies to:

  • All WHO2 employees, directors and officers

  • All contractors, consultants and associates

  • All subcontractors and freelance workers

  • All suppliers, introducers and referral partners

  • Any third party acting on behalf of WHO2

It covers all geographies where WHO2 operates or sources services.

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3. Zero-Tolerance Statement

WHO2 prohibits:

  • Use of forced, bonded or compulsory labour

  • Human trafficking or exploitation of any person

  • Employment practices that deny individuals their rights

  • Withholding of identification documents or payments

  • Exploitative recruitment or working arrangements

  • Child labour

  • Any form of discrimination, abuse or intimidation

  • Engaging suppliers who cannot demonstrate ethical labour practices

WHO2 will not knowingly work with any organisation involved in modern slavery or human trafficking.

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4. Definitions

Modern Slavery:
Situations where individuals are exploited and cannot refuse or leave work due to threats, coercion, abuse of power or deception.

Human Trafficking:
Recruitment, transportation, transfer, harbouring or receipt of persons for the purpose of exploitation.

Forced Labour:
Work performed involuntarily under threat of penalty.

Child Labour:
Employment of individuals below legal working age or in hazardous conditions.

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5. WHO2’s Risk Profile

Although WHO2 is a professional services and consultancy business, risks may arise through:

  • Subcontractors delivering consultancy or technical services

  • Freelance personnel sourced internationally

  • External third-party suppliers (e.g., IT, design, support services)

  • Introducers and agents operating in higher-risk jurisdictions

  • Outsourced teams

  • Recruitment via third-party agencies

WHO2 manages these risks through due diligence and supplier controls.

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6. Responsibilities

The WHO2 Board

  • Oversees compliance with this policy

  • Ensures appropriate risk assessments and mitigation measures

Chief Executive Officer/Chief Technology Officer

  • Lead on modern slavery compliance

  • Ensure due diligence is conducted on suppliers and subcontractors

  • Provide training and updates

All WHO2 Representatives

  • Must comply with this policy

  • Must report any concerns or suspicions immediately

  • Must avoid engaging suppliers or subcontractors who cannot demonstrate ethical practices

Suppliers, Subcontractors and Introducers

  • Must maintain labour standards equivalent to WHO2’s expectations

  • Must not engage in or facilitate modern slavery

  • Must permit monitoring or verification where required

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7. Supplier and Subcontractor Due Diligence

WHO2 conducts proportionate due diligence on all subcontractors, introducers and suppliers. This may include:

  • Verification of identity and legal status

  • Review of employment practices

  • Confirmation of payment of statutory wages

  • Verification that staff are working voluntarily

  • Confirmation of the right to work

  • Checks for indicators of coercion or exploitation

  • Ensuring subcontractors have their own modern slavery/corporate responsibility policies

  • Agreement to WHO2 contractual obligations and flow-down clauses

WHO2 reserves the right to terminate contracts where concerns arise.

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8. Indicators of Modern Slavery (Red Flags)

Personnel should be alert to signs including:

  • Workers appearing intimidated, fearful or unable to speak freely

  • Confiscated passports or identification documents

  • Workers living at their workplace or in unsuitable accommodation

  • Unexplained deductions from wages

  • Recruitment fees charged to workers

  • Workers who do not possess their employment contract

  • Third-party “handlers” speaking on behalf of individuals

  • Signs of physical or psychological abuse

  • Workers who are prevented from leaving employment

Any suspicion must be reported immediately.

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9. Reporting Concerns

Any concern relating to modern slavery or trafficking should be reported immediately to, info@who2global.co.uk

 

Concerns may also be raised through the WHO2 Whistleblowing Policy.

WHO2 treats all reports seriously and confidentially. Retaliation against anyone raising a concern in good faith is prohibited.

Where criminal activity is suspected, WHO2 may notify:

  • Local law enforcement

  • The Modern Slavery Helpline (UK)

  • Relevant regulatory or safeguarding authorities

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10. Investigation and Corrective Action

Upon receiving a report, WHO2 will:

  1. Acknowledge the concern

  2. Conduct an initial risk assessment

  3. Initiate an investigation if necessary

  4. Engage with suppliers or subcontractors to gather information

  5. Suspend or remove individuals or suppliers where required

  6. Report to authorities if a crime is suspected

  7. Document findings and remediation actions

  8. Review and strengthen controls to prevent recurrence

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11. Training and Awareness

WHO2 will provide:

  • Annual awareness training for employees and contractors

  • Induction training for new starters

  • Additional training for high-risk roles (e.g., subcontractor onboarding, recruitment, supply chain management)

  • Access to resources explaining indicators of exploitation

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12. Record Keeping

WHO2 will securely maintain:

  • Supplier due diligence documentation

  • Subcontractor and introducer onboarding information

  • Records of concerns raised and actions taken

  • Training records

  • Updated risk assessments

Records will be retained in accordance with the WHO2 Data Retention Policy.

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13. Policy Monitoring and Review

WHO2 will:

  • Review this policy annually

  • Update procedures following legal or operational changes

  • Reassess risks where new suppliers or subcontractors are engaged

  • Report material concerns to the WHO2 Board

Approval rests with the WHO2 Board.

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