Modern Slavery Statement

Scope of this statement

Section 54 of the Modern Slavery Act 2015 requires a slavery and human trafficking statement from commercial organisations with a total annual turnover of £36 million or more. ActiveManage Ltd is below that threshold, so this statement is voluntary and is not made under section 54.

We publish it because our customers include NHS trusts and other public bodies whose own procurement rules require them to understand their supply chain, and because the exercise of writing it is worth doing regardless of whether a statute compels it.

This statement covers the financial year ending 31 October 2025 and applies to the whole of ActiveManage Ltd. We have no subsidiaries.

Our business

ActiveManage Ltd (company number 10448163) is a software company registered in England and Wales, with its registered office at ActiveManage Ltd., Enterprise Centre, David Lane, Basford, Nottingham, NG6 0JU. We build and operate the ActiveManage low-code development platform, and we deliver bespoke business applications on it.

Everyone who works for us is employed in the UK. All staff are directly employed on contracts that meet or exceed statutory minimums, paid at or above the National Living Wage, and hold the right to work in the UK, verified before employment begins. We do not use employment agencies for temporary or seasonal labour, and we do not operate in any sector conventionally associated with a high risk of forced labour.

Our supply chain

Our supply chain is short, and almost all of our spend falls into five categories:

We do not manufacture anything, hold physical stock, or operate a logistics or distribution network. We do not employ or contract labour outside the UK. No development, testing, support or data-processing work is subcontracted offshore, to anyone: all of it is carried out in the UK by our own directly employed staff.

Where the risk actually is

It would be easy, and not very useful, to conclude that a UK software company has no modern slavery risk. Two areas are worth naming honestly:

• Facilities services. We occupy serviced office space, which means the cleaning, security, catering and maintenance contracts are let by our landlord rather than by us. These are labour sectors with a documented history of exploitation, and they are the part of our supply chain where we have real exposure and the least direct control.
• Hardware manufacture and mineral extraction. Every laptop we buy has a supply chain reaching into electronics assembly and, beyond that, mineral extraction. Our purchasing volume gives us no leverage over it, but pretending the risk is not there because we cannot influence it would be dishonest.

Beyond that, the standard indicators of forced labour — recruitment fees, withheld documents, tied accommodation, unexplained deductions, third-party control of wages — do not arise in a directly employed UK professional workforce, which is what we are.

The steps we take

• Right-to-work checks on every employee before employment starts, with records retained.
• Direct employment. We do not engage labour through agencies, umbrella companies or intermediaries where visibility of terms and pay would be reduced.
• Supplier screening at onboarding. For any new supplier above £10,000 annual spend we check for a published modern slavery statement or, where the supplier is below the threshold as we are, an equivalent commitment.
• Contractual terms. Our standard supplier terms require compliance with the Modern Slavery Act 2015 and the right to terminate for a breach.
• Preference for UK and EU suppliers where a comparable service exists, which shortens the chain and puts more of it inside a regulated labour market.
• A reporting route. Any employee, contractor or supplier can raise a concern to David Hill at info@activemanage.co.uk. Concerns can be raised anonymously and are covered by our whistleblowing procedure, which protects the person raising them.
• We raise facilities services with our landlord as part of the annual review of this statement, and ask what assurance they hold over the contracts they let on our behalf.

Training and awareness

Everyone involved in purchasing or in engaging people is briefed on the indicators of forced labour and on how to raise a concern. Given our size this is a briefing and a written procedure rather than a formal training programme, and we would rather describe it accurately than call it something grander.

Measuring effectiveness

We track three things, and report them in this statement each year:

• The proportion of supplier spend covered by a modern slavery statement or equivalent commitment. The large majority: most of what we spend goes to major software and infrastructure providers, all of which are well above the section 54 threshold and publish a statement. We report this as a proportion rather than a percentage because we have not yet counted it to a precision a percentage would imply.
• The number of concerns raised through any route, and their outcome. In the year covered by this statement: none.
• Whether every new supplier onboarded in the year was screened. In the year covered by this statement: not recorded. Screening is part of onboarding, but we did not keep a supplier-by-supplier record of it for this period and will not claim one retrospectively. We are keeping that record from now on, and next year this line will be a yes or a no.

These are deliberately small, countable measures. A company of our size that claimed a comprehensive audit programme would not be believed, and should not be.

Approval

This statement was approved by the board of ActiveManage Ltd on 7 September 2026 and is reviewed annually.

Signed: David Hill, Managing Director, for and on behalf of ActiveManage Ltd.

A signed PDF of this statement, on letterhead, is available from info@activemanage.co.uk for procurement portals that require an uploaded document rather than a URL.