Modern Slavery and Human Trafficking Policy

Purpose

Modern slavery is a crime and a violation of fundamental human rights, taking forms including slavery, servitude, forced or compulsory labour, and human trafficking. This policy sets out Deliverance AI Limited's commitment to acting ethically and with integrity in all business relationships, and to implementing effective controls to ensure modern slavery is not taking place in our business or supply chains.

Scope

This policy applies to all individuals working for or on behalf of Deliverance AI at all levels, and we expect the same standards from our contractors, suppliers, and other business partners.

Policy statement

Deliverance AI has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all business relationships and to implementing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or supply chains, consistent with our obligations under the Modern Slavery Act 2015.

Definitions

Slavery is the exercise of powers of ownership over a person. Servitude is the obligation to provide services imposed by coercion. Forced or compulsory labour is work exacted under menace of a penalty and not offered voluntarily. Human trafficking is arranging or facilitating travel of another person with a view to their exploitation.

Responsibility for this policy

The board has overall responsibility for ensuring this policy complies with our legal and ethical obligations. The policy owner has day-to-day responsibility for implementing it, monitoring its effectiveness, and responding to any concerns.

Our business and risk

Deliverance AI is a UK-based, remote-first enterprise software and AI company. Our workforce is engaged under formal contracts compliant with UK employment law, placing our own operations at low inherent risk. Our principal exposure is indirect, through our supply chain, for example hardware, equipment, facilities, and subcontracted services, which we manage on a risk-prioritised basis.

Due diligence and supplier expectations

Taking a risk-based approach to suppliers and third parties, we may identify and assess risk areas; require confirmation of compliance with applicable anti-slavery laws and the principles in this policy; include appropriate contractual provisions and rights to terminate; and monitor and take corrective action where concerns arise.

Your responsibilities

You must read, understand, and comply with this policy. Preventing, detecting, and reporting modern slavery in our business or supply chains is everyone's responsibility. You must notify the policy owner as soon as possible if you believe or suspect a conflict with this policy.

Raising a concern

Raise concerns about modern slavery at the earliest possible stage by emailing trust@deliverance.ai. We support anyone who raises a genuine concern in good faith and will not tolerate detrimental treatment as a result.

Training and communication

Our zero-tolerance approach is communicated to staff at the outset of their work and reinforced as appropriate, and to suppliers and partners at the outset of our relationship with them. Relevant training is provided so staff understand the risks of modern slavery.

Breaches

Any breach may result in disciplinary action up to dismissal for staff, and termination of the relationship for other individuals and organisations working on our behalf.

Legal status

This policy reflects our commitment under the Modern Slavery Act 2015. The statutory requirement to publish an annual modern slavery statement applies only to organisations with annual turnover of £36 million or more. Deliverance AI does not currently meet that threshold and is not legally required to publish a statement; we maintain this policy as good practice and to meet customer expectations. Where an enterprise customer specifically requires a published Modern Slavery Statement, one can be produced as a separate board-approved document on request.