Statement on Modern Slavery & Trafficking and Transparency in the Supply Chain

This statement is intended to comply with the requirements of the Modern Slavery Act 2015 and sets out UDlive's position. The statement is reviewed annually and formally approved by the management board every year.

OUR GENERAL POSITION

We acknowledge and agree that slavery and forced labour (as defined by Article 4 of the Convention on Human Rights) are rightly to be treated as offences, and we recognise that in determining whether "slavery" or "forced labour" situations exist, account must be taken of all the circumstances of the case including any vulnerability of the individual.

We acknowledge and agree that human trafficking is rightly to be treated as an offence, and understand that human trafficking is the arranging of the transport of a person with a view to their being exploited, or in the knowledge that they will be exploited. Exploitation is defined as:

  • slavery;
  • forced labour;
  • sexual exploitation (defined by reference to other UK Acts);
  • removal of organs;
  • securing services by force, threats or deception;
  • securing services by any means from a child or vulnerable person (as defined).

As these occurrences may arise within our supply chain — that is, be carried out by contractors, sub-contractors, sub-sub-contractors (and so on) and/or suppliers, sub-suppliers (and so on) — we have a moral duty to do what we can to ensure we are not complicit, so far as we are reasonably able to do so.

COMPANY POLICY

UDlive is fully committed to eliminating modern slavery, human trafficking, forced labour and similar human rights abuses, and we have a zero tolerance approach to modern slavery and human trafficking.

UDlive recognises the key responsibility it has within the supply chain of skilled labour and professionals to ensure that all individuals sourced, procured or engaged are treated fairly, ethically and in compliance with legislative requirements.

Throughout its core businesses UDlive holds itself accountable for ensuring that it and third-party suppliers are aware of the impact and requirements of the Modern Slavery Act 2015.

COMPANY TRAINING

UDlive directors, senior managers and employees are given training to raise awareness of individual and collective responsibilities under the Modern Slavery Act 2015.

The training is mandatory for all employees during the first six months of their employment. We ensure that we are prepared to engage our clients and third-party suppliers to achieve alignment in the procurement and supply chain to address respective responsibilities of the Modern Slavery Act 2015, in order to implement and maintain an effective and transparent process of compliance.

OUR POLICIES

UDlive maintains the following policies, which are provided to our staff upon joining our business.

Code of Conduct

The fundamental principle in our code of conduct policy is that all business conducted by members of UDlive must meet the highest moral and ethical standards and comply with the law. UDlive is committed to eliminating unethical behaviour and conflict of interest within our organisation, and we encourage employees to disclose any such activities.

Diversity and equality policy

The policy aims to eliminate discrimination in the employment of new staff. Through the policy we enforce our strong belief that the qualifications, merit and experience of an applicant should be the sole criteria when putting forward an applicant for employment or engagement.

Human rights policy

The policy promotes sound ethical values and human rights principles to our staff:

  • Employees should conduct themselves in accordance with the highest ethical standards.
  • No discrimination is practised within our organisation.
  • Employment is freely chosen. No forced, bonded or involuntary prison labour is permitted.
  • Our employees are able to work in an environment free of physical, psychological or verbal abuse, the threat of abuse and sexual or other harassment; accordingly, these are prohibited.
  • UDlive prohibits the use of all forms of forced labour, including prison labour, indentured labour, bonded labour, military labour, slave labour and any form of human trafficking.
  • Employees shall be paid wages and benefits for a standard working week that meet national minimum requirements.
  • Employees shall be informed of their working conditions in a written and understandable format with respect to their wages and the circumstances of each payment.
  • Child labour is prohibited.

Whistleblowing policy

The policy encourages staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be protected wherever possible. This includes instances of modern slavery or human trafficking.

SUPPLY CHAIN DUE DILIGENCE

UDlive aims to work with only those suppliers that demonstrate high levels of commitment to monitoring and reducing the risk of modern slavery and human trafficking taking place within their organisations or supply chains. As a pre-condition to supplying UDlive, suppliers must confirm their compliance with the Act. If a supplier fails to provide the information requested or meet UDlive's expectations, UDlive will take appropriate action, which may include not entering into a relationship or terminating the relationship.

MOVING FORWARD

During the course of 2025–2026, UDlive will:

  • continue to strengthen our training materials and raise our staff awareness about modern slavery and trafficking;
  • collaborate with our clients in this area;
  • strengthen the due diligence for new suppliers;
  • as part of our efforts in this area, publish a modern slavery statement on an annual basis.

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