Modern Slavery and Human Trafficking Statement

Reporting period: Financial Year 2025

Statement version: v2.0 Approved

Publication date: 7 July 2026

Next review: 7 July 2027

Approved by: Chris Price, Managing Director, Cranmore Consulting Ltd

Introduction

Cranmore Consulting Ltd is committed to preventing modern slavery and human trafficking in all our business activities and supply chains. We uphold the highest standards of ethical conduct in our own operations and expect the same of our partners and suppliers.

Although exempt from section 54 of the Modern Slavery Act 2015 we nonetheless publish this Statement voluntarily, in the format prescribed by s54 and covering the six areas identified in Home Office guidance, because we consider transparent reporting to be part of responsible business practice and because our public sector customers value the assurance it provides.

This Statement is approved by the Managing Director and reviewed annually.

Our organisation and business

Cranmore Consulting Ltd (Company Registration NI070910) is a Northern Ireland-based digital solutions company, headquartered at 73 Church View, Holywood, County Down, BT18 9LN. Founded in 2008, Cranmore employs approximately 40-50 staff, all directly employed on permanent or fixed-term contracts, all paid at or above the Real Living Wage, and all working in the United Kingdom.

We provide AI transformation, managed digital services, and consultancy and Discovery for public sector clients across the UK and Ireland — including local government, health, justice, transport, utilities and regulatory bodies. We do not manufacture, import, or distribute physical goods at scale, and we do not operate in sectors historically associated with elevated modern slavery risk such as construction, agriculture, hospitality, or garment manufacture.

We deliver services predominantly from the Holywood office and from staff home offices, with occasional short visits to client premises across the UK. We do not sub-contract delivery of software services; all delivery is undertaken by directly employed Cranmore staff.

Our supply chains

Cranmore’s supply chain is stable, UK-based and concentrated in categories that are low-risk for modern slavery. The principal supplier categories are:

• Software and cloud infrastructure: Microsoft (Azure, Microsoft 365, Dynamics 365, Power Platform), Atlassian (JIRA, Confluence), GitHub — all large, publicly listed technology providers subject to their own s54 statements and mature supplier assurance regimes.
• Professional services: UK-registered accountancy, legal, insurance and banking providers.
• Facilities and office services (Holywood): cleaning, waste and WEEE recycling, portable appliance testing, fire safety servicing, IT hardware maintenance — engaged with local Northern Ireland suppliers under direct contracts with verified insurances.
• Business travel and hospitality: engaged through UK-based providers under standard corporate travel arrangements.
• Recruitment: Cranmore’s staff are recruited directly. Where recruitment agencies are used, they are UK-registered and REC-affiliated.

Cranmore has no manufacturing supply chain, no operations in high-risk jurisdictions identified by the Global Slavery Index or the International Labour Organization, and no reliance on migrant, seasonal or agency labour.

Our policies

Cranmore’s policy framework relating to modern slavery and ethical sourcing comprises:

• This Modern Slavery and Human Trafficking Statement.
• Supplier Code of Conduct, containing express prohibitions against forced labour, child labour, human trafficking, and any labour practice inconsistent with the International Labour Organization’s core conventions.
• Whistleblowing Policy, providing confidential and non-retaliatory routes for staff, workers and third parties to report concerns.
• Recruitment and Employment Policy, including right-to-work verification for all new joiners and a direct-employment model for permanent staff.
• Equality, Diversity and Inclusion Policy, prohibiting discrimination and supporting fair treatment across recruitment, employment and service delivery.
• Ethics and Business Conduct provisions within Cranmore’s Quality Management System (aligned with ISO 9001:2015), which set expectations for the conduct of directors, staff and contractors.
• Information Security policies under Cranmore’s ISO/IEC 27001:2022 Information Security Management System (certified March 2026), which incorporate supplier-management controls covering ethical conduct alongside data protection.

Policies are reviewed at least annually as part of the integrated Information Security and Quality Management System Management Review cycle, and made available to all staff through Cranmore’s internal document management system.

Due diligence processes

Cranmore’s due diligence process is proportionate to our size, sector and supply chain risk profile:

• New suppliers are subject to a competence and integrity check before engagement, including sight of business registration, relevant insurances, and, where the supplier processes personal data, an information security questionnaire and Data Protection Addendum aligned to Cranmore’s ISO 27001 supplier management control.
• The Supplier Code of Conduct is issued to new suppliers at onboarding and re-issued at material contract renewal, with acceptance recorded.
• Existing suppliers are reviewed on a defined cycle, with higher-risk or higher-value suppliers reviewed more frequently and lower-risk suppliers reviewed at contract renewal.
• Where indicators of modern slavery, human trafficking, or unethical practice are identified — directly, through third-party sources, or through media reporting — Cranmore requires evidence of remediation. Where evidence is not forthcoming, or the finding is severe, Cranmore disengages the supplier.

Due diligence records are held within Cranmore’s supplier register and available on request to clients, regulators or auditors.

Risk assessment and management

Given Cranmore’s UK-only operations, direct-employment model, and concentration in low-risk supplier categories, no material modern slavery risk has been identified within our business or its direct supply chain. Residual risks and the management steps applied to them are:

• Cleaning and facilities providers. The cleaning services sector is recognised by the Home Office as elevated-risk for modern slavery. Cranmore engages a single Northern Ireland-based cleaning provider with a direct-employment model, verified insurances, and confirmed Real Living Wage commitment. This supplier is reviewed annually.
• Indirect exposure through IT hardware manufacturing supply chains (Microsoft, Dell and other original equipment manufacturers). This exposure is multi-tier and beyond Cranmore’s direct visibility. Cranmore relies on each OEM’s own published Modern Slavery Statement and their participation in the Responsible Business Alliance auditing regime as the primary control.
• Future engagement with sub-contractors under any Framework or Call-off contract. Cranmore does not currently sub-contract delivery. Where sub-contracting is introduced in future, Modern Slavery obligations will be flowed down through sub-contract terms as a standard clause.

Risk assessment is refreshed annually and following any material change to Cranmore’s operations, supplier base, or delivery model.

Effectiveness measurement

Cranmore measures the effectiveness of its modern slavery arrangements through the following indicators, reviewed at annual Management Review:

• Supplier Code of Conduct acceptance rate — proportion of contracted suppliers who have accepted the Code at onboarding or renewal.
• Whistleblowing report volume — number of reports received through Cranmore’s whistleblowing channel in the reporting period, and any relating to modern slavery indicators.
• Staff training completion rate — proportion of new joiners who have completed modern slavery awareness at induction; proportion of all staff who have completed annual refresher training.
• Policy review currency — the date this Statement, the Supplier Code of Conduct and the Whistleblowing Policy were last reviewed and approved.
• Supplier disengagement events — number of suppliers disengaged in the reporting period on ethical or modern slavery grounds.

Position at the date of this Statement:

• Zero substantive modern slavery reports received through any channel during the reporting period.
• Modern Slavery Statement, Supplier Code of Conduct and Whistleblowing Policy all reviewed within the preceding twelve months.
• Staff awareness maintained through structured induction and annual refresher training.

Training and awareness

Modern slavery awareness is embedded in Cranmore’s staff development at three points:

• Induction. All new joiners complete a modern slavery awareness briefing during induction, covering: what modern slavery and human trafficking are; the indicators to look for within our operations, customers and supply chains; how to raise a concern (line manager, HR, whistleblowing channel); and the assurance that reports will be treated in confidence and without retaliation.
• Annual refresher. All staff complete a modern slavery awareness refresher at least annually, delivered through Cranmore’s internal training platform.
• Targeted training for supplier-facing roles. Staff engaged in procurement, supplier management or contract administration receive additional guidance on due diligence and Supplier Code of Conduct application.

Training completion is recorded within Cranmore’s Competency Matrix, evidenced under Clause 7 of the Quality Management System attestation issued by Instil Software Ltd in June 2026.

Continuous improvement

Cranmore is committed to continuous improvement in our approach to combatting modern slavery. This Statement, the Supplier Code of Conduct and the underpinning policies will be reviewed and updated at least annually, and additionally following any material change to our business, supplier base or operating environment. Improvements identified through internal audit, whistleblowing reports, supplier engagement or external guidance will be incorporated into successive versions of this Statement.

Approval

This Modern Slavery and Human Trafficking Statement has been reviewed and approved by the Managing Director of Cranmore Consulting Ltd.

Name: Chris Price

Position: Managing Director, Cranmore Consulting Ltd

Date: 7 July 2026

This Statement will be reviewed by 7 July 2027.