Modern Slavery Policy & Statement

Organisation

iO-Sphere Limited

UKPRN

10094788

Document owner

James Cotton, Managing Director

Approved by

James Cotton, Managing Director

Version

1.0

Effective

15 April 2026

Next review

15 April 2027

1. Introduction and Commitment

iO-Sphere Limited ("iO-Sphere") is a specialist data and AI training provider delivering apprenticeships, Skills Bootcamps, Higher Technical Qualifications and commercial programmes across England. We are committed to conducting all business activities ethically and with integrity, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

This document serves as both our organisational policy on modern slavery and our annual statement made pursuant to Section 54 of the Modern Slavery Act 2015. While iO-Sphere is not currently required by statute to publish a modern slavery statement (the Act mandates statements from organisations with annual turnover of £36 million or more), we voluntarily publish this statement as a demonstration of our commitment to transparency and ethical business practices, and in line with the expectations of our funding bodies, contracting authorities and partners.

2. Scope

This policy applies to all persons working for or on behalf of iO-Sphere in any capacity, including:

• Directors and senior leadership
• Employees (full-time, part-time and fixed-term)
• Associate trainers, coaches, assessors and practitioners
• Contractors, consultants and agency workers
• Volunteers and work experience placements

It also extends to our supply chain, including subcontractors, recruitment agencies, technology vendors, venue providers and any other third parties with whom iO-Sphere has a business relationship.

3. Definitions

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, 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. Under the Modern Slavery Act 2015, the following offences are defined:

• Slavery: the exercise of powers of ownership over a person.
• Servitude: the obligation to provide services imposed by coercion.
• Forced or compulsory labour: work or service exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.
• Human trafficking: arranging or facilitating the travel of another person with a view to that person being exploited.

4. Our Organisation and Supply Chains

iO-Sphere is a UK-based company headquartered in London. Our principal activities are the design and delivery of vocational education and training programmes in data, analytics and artificial intelligence. Our workforce consists primarily of UK-based employees and associate practitioners who deliver training either in person or remotely.

Our supply chain is predominantly UK-based and includes:

• Technology and software providers (learning platforms, cloud services, SaaS tools)
• Awarding organisations and qualification bodies
• Venue and facilities providers for in-person delivery
• Recruitment agencies for permanent and associate staff
• Professional services providers (legal, accounting, marketing)
• Office supplies and equipment providers

We assess our supply chain as relatively low risk for modern slavery given its predominantly UK-based, professional-services nature. However, we recognise that modern slavery can occur in any sector and remain vigilant accordingly.

5. Our Policies and Procedures

iO-Sphere maintains the following policies and procedures which contribute to our approach to identifying and preventing modern slavery:

• Safeguarding and Prevent Policy — includes procedures for identifying and responding to concerns about exploitation and trafficking, particularly among our learner population.
• Recruitment and Selection Policy — includes robust verification of identity, right to work documentation and employment history to prevent exploitation.
• Whistleblowing Policy — provides a mechanism for staff, learners and stakeholders to raise concerns about any wrongdoing, including suspected modern slavery, without fear of retaliation.
• Code of Conduct — sets out the standards of behaviour expected of all staff and associates.
• Procurement and Supplier Management — requires due diligence on new and existing suppliers, including consideration of modern slavery risks.
• Equality, Diversity and Inclusion Policy — reinforces our commitment to treating all people with dignity and respect.

6. Due Diligence Processes

iO-Sphere undertakes the following due diligence measures to identify and mitigate the risk of modern slavery:

1. Supply chain risk assessment: We evaluate our supply chain to identify areas of potential risk, considering sector, geography and the nature of services provided.
2. Supplier due diligence: New suppliers are assessed against modern slavery criteria. Where appropriate, we request confirmation that suppliers have their own modern slavery policies and practices in place.
3. Contractual provisions: Our standard terms and conditions require suppliers to comply with all applicable laws, including the Modern Slavery Act 2015, and to permit audit of their compliance.
4. Recruitment checks: All employees and associates undergo right to work checks, identity verification and reference checks. We do not use practices that could indicate forced labour, such as retaining identity documents or requiring payment for work equipment.
5. Learner safeguarding: Our safeguarding framework includes awareness of exploitation indicators among our learner population, with designated safeguarding leads trained to identify and escalate concerns.

7. Risk Assessment and Mitigation

We have assessed the modern slavery risk across our operations and supply chain. While our overall risk profile is low given our sector and geographic footprint, we have identified the following areas requiring ongoing vigilance:

8. Training and Awareness

iO-Sphere is committed to ensuring that staff at all levels understand the risks of modern slavery and their responsibilities under this policy:

• All staff receive modern slavery awareness training as part of their induction, covering how to identify signs of modern slavery and how to report concerns.
• Designated Safeguarding Leads (DSLs) receive enhanced training on exploitation, trafficking and modern slavery indicators.
• Coaches and assessors who work directly with learners and employers receive training on recognising signs of exploitation in workplace settings.
• Refresher training is provided annually and updated as necessary to reflect changes in legislation or guidance.

9. Reporting Concerns

iO-Sphere encourages all staff, learners, stakeholders and members of the public to report any concerns or suspicions of modern slavery. Reports can be made through the following channels:

• Directly to any member of the senior leadership team
• Through the company's whistleblowing procedure (anonymous reporting available)
• To a Designated Safeguarding Lead
• To the Modern Slavery Helpline: 08000 121 700
• To the police by calling 101 (or 999 in an emergency)

All reports will be investigated promptly and treated with the utmost confidentiality. No individual will suffer any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery may be occurring.

10. Breach of This Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. iO-Sphere may terminate its relationship with any supplier, contractor or other third party found to be involved in modern slavery.

11. Monitoring and Review

This policy and statement will be reviewed annually by the Managing Director to ensure it remains effective and relevant. As part of this review, we will:

• Evaluate the effectiveness of the measures described in this policy
• Consider whether additional measures are required in light of any changes to our business or supply chain
• Update our risk assessment to reflect any new or emerging risks
• Report on any incidents or concerns raised during the review period

12. Statement and Approval

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes iO-Sphere Limited's modern slavery and human trafficking statement for the financial year ending April 2026.

This statement has been approved by the board of directors (or equivalent governing body) of iO-Sphere Limited.

Approved by James Cotton, Managing Director, iO-Sphere Limited, on 15 April 2026.