1. Introduction

   1. Stellarmann Group Ltd and its subsidiaries Stellarmann Professional Services Ltd & William Alexander Recruitment Ltd (Stellarmann Group) is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring its supply chains are free from slavery and human trafficking.

   2. This statement outlines the actions taken by Stellarmann Group during the 2025-2026 financial year to identify, prevent and address risks of modern slavery and human trafficking across our operations and supply chains.

       

2. The Modern Slavery Act 2015

   1. Modern slavery includes a range of types of exploitation, many of which occur together. These include but are not limited to: 

   2. Sexual exploitation: This includes sexual abuse, forced prostitution and the abuse of children to produce child abuse images/videos.

   3. Domestic servitude: this involves victims being forced to work in usually private households, performing domestic chores and childcare duties. 

   4. Forced labour: This can happen in various industries, including construction, manufacturing, laying driveways, hospitality, food packaging, agriculture, maritime and beauty (nail bars). 

   5. Criminal exploitation: This can be understood as the exploitation of a person to commit a crime, such as pick-pocketing, shoplifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker. 

   6. Other forms of exploitation include organ removal, forced begging fraud, marriage, and illegal adoption.

   7. These forms of exploitation often overlap, and vigilance is required across all functions of the organisation.

       

3. Organisational structure & supply chains

   1. The statement covers direct employees of Stellarmann Group, agency workers; and services delivered on behalf of Stellarmann Group by third party organisations and in the company’s supply chains.

   2. Stellarmann Group engages in commercial activities by providing services delivered directly by employees and through external contractors; its annual turnover is less than £36million.

   3. The organisations supply chain primarily consists of UK‑based professional service providers, IT suppliers, training providers and contractors, all operating within low‑risk sectors.

   4. Structure

      1. Stellarmann Group is made up of Stellarmann Group, William Alexander Recruitment & Stellarmann Professional Services. All operate solely from the United Kingdom. 

4. Countries of operation & supply

   1. Stellarmann Group is based in Brighton, in the county of Sussex, United Kingdom: Whilst the risk of slavery and human trafficking is considered low, Stellarmann Group remains vigilant and will take all steps available to manage the risks presented. 

   2. High-Risk Activities

      1. Stellarmann Group will conduct dynamic risk assessments of their activities in assessing whether or not particular activities are high risk in relation to slavery or human trafficking. Any concerns should be raised initially with the officer responsible for Safeguarding. 

      2. The following activities are considered to be at high risk of slavery or human trafficking:

      3. Risk assessments consider sector, geography, type of labour, and supplier dependency. Based on this assessment, no high‑risk activities have been identified to date.

   3. Responsibility

      1. Responsibility for the organisation’s anti-slavery initiative is as follows:

      2. Policies: Stellarmann Group’s Senior Management Team is responsible for reviewing this policy and the Operations Director is responsible for keeping under review contract procedures where a risk is identified in the supply chain. This policy will be reviewed on an annual basis or when legislation changes. 

      3. Risk assessments/investigations/due diligence: It is the responsibility of the Operations Director alongside the Senior Management Team to ensure that procurement processes are robust in identifying risks in relation to slavery and human trafficking and explain their specific role. 

      4. Responsibility: It is the responsibility of the employee responsible for Safeguarding to ensure any risks or issues identified outside of the supply chain are dealt with appropriately and in a timely fashion and in accordance with safeguarding procedures. 

      5. Training: Stellarmann Group has a programme of safeguarding training for employees that enables them to identify and know how to report suspected or disclosed incidents of abuse and neglect, including modern slavery and human trafficking.

          

5. Relevant Policies

   1. The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

   2. Whistleblowing policy: The organisation encourages all its employees to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees can raise the concerns through the mechanisms outlined in the Public Interest Disclosure (Whistleblowing) Policy.

   3. Conduct and Standards policy: The organisation's policy makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

   4. Employee Recruitment and Selection Policy: The organisation uses only reputable employment agencies to source labour.

   5. Anti-Bribery Policy: Preventing bribery and corruption helps ensure that no form of coercion, exploitation or undue influence contributes to modern slavery risks within our operations or supply chains.

   6. Data Protection Policy: Protecting personal data reduces the risk of misuse or unauthorised access to sensitive information that could expose individuals to exploitation or trafficking.

   7. Supplier Code of Conduct: Setting clear ethical and labour‑standard expectations for all suppliers, helping ensure they operate in ways that prevent slavery, forced labour and human rights abuses.

       

6. Due Diligence

   1. Stellarmann Group’s due diligence approach to procurement includes a requirement to comply with this Modern Anti-Slavery and Human Trafficking Statement where turnover is less than £36million. Where turnover is more than £36 million due diligence includes ensuring suppliers have their own modern slavery procedures in place.

   2. The organisation undertakes due diligence when entering into contracts with suppliers, and contract manages to ensure adherence to the Key Performance Indicators.

   3. The organisation's due diligence and reviews include: 

      1. Mapping the supply chain broadly to assess products or geographical risks of modern slavery and human trafficking. 

      2. Ensure key suppliers confirm their adherence to Modern Day Slavery Act 2015 and human trafficking risks by reviewing on an ad hoc basis aspects of the supply chain 

      3. Contractors are required to hold relevant insurance cover required and will continue to for life of the contract. 

      4. Where contractors use sub‑contractors, the organisation expect them to apply equivalent due diligence standards.

          

7. Key Performance Indicators (KPIs)

   1. Stellarmann Group uses the following performance indicators to measure how effective it has been to ensure that slavery and human trafficking is not taking place in any part of its business or supply chains: 

      1. All Employees & suppliers confirming their adherence to Modern Day Slavery Act (2015) 

      2. Employees made aware of Modern-Day Slavery Act 2015 and training provided as identified

      3. All employees completed induction training

      4. Number of cases reported (whistleblowing) and resulting action

          

8. Training

   1. Stellarmann Group has a programme of mandatory equality, diversity & Inclusion training for employees that enables them to identify and know how to report suspected or disclosed incidents of abuse, discrimination, bullying and neglect

   2. Stellarmann Group has a programme of staff training specific to modern slavery and human trafficking. This includes raising awareness of:

      1. the basic principles of the Modern Slavery Act 2015 and the company’s duties. 

      2. how employees can identify slavery and human trafficking and what to do if they have concerns.

      3. what external help is available, for example through the modern slavery helpline.

          

9. Reporting Modern Day Slavery

   1. If you suspect modern slavery, please report to management as outlined in the Public Disclosure (Whistle Blowing) policy or report it to the Modern Slavery Helpline on 08000 121 700.  This helpline may also be used to seek advice.

   2. All reports are fully investigated within 5 working days of the company becoming aware and appropriate remedial actions taken where required.

   3. Where a concern is raised, we prioritise safety, confidentiality and access to appropriate support services.

       

10. Breaches of this Policy/Statement

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

    2. We expect the same standards from all parties in our supply chain and will take appropriate action, including termination, where suppliers fail to meet our expectations.

        

11. Standards

    1. Stellarmann Group will meet the following standards and expects those with whom it does business with, to meet these standards:

    2. To support every individual’s human right to live free from abuse, servitude and inhumane treatment,

    3. To ensure a Diversity & Inclusion policy (or equivalent) is provided to all employees

    4. To adhere to local and national laws including:

    5. Prohibiting the use of worker-paid recruitment free

    6. Prohibiting compulsory overtime

    7. Prohibiting confiscation of workers original identification documents

    8. To promote ethical business and operational practices in corporate activity and the services delivered, this includes:

       1. Freedom of workers to terminate employment

       2. Freedom of movement

       3. Freedom of Association

    9. To take appropriate steps to ensure that slavery and human trafficking is not taking part in any of its business or supply chains,

    10. To take reports of witnessed, suspected or disclosed concerns of slavery and human trafficking seriously,

    11. To take appropriate steps to address actual instances of slavery and human trafficking & provide access to remedy, compensation & justice for victims.

     

12. Continuous Improvement 

    1. We will continue to strengthen our processes by expanding supplier due diligence, enhancing training and improving visibility across our contractor supply chain.

        

13. Board Approval

This statement applies to the financial year 2025 - 2026 and will be reviewed before January.

Approved: 03/02/2026

Version: 15.0

Review Date: 03/02/2027