This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Grayce Group Limited has taken during the year ended 31 March 2026 to help prevent modern slavery and human trafficking in its business operations and supply chains.
Grayce has a zero-tolerance approach and active commitment to preventing acts of modern slavery and human trafficking from occurring either directly through our business or through our supply chain. Grayce is committed to imposing the same high standards on suppliers at all times.
Whilst Grayce is ultimately responsible for ensuring there is no risk of modern slavery and human trafficking, we expect our employees to be accountable for compliance with our related policies.
Employment must be a voluntary choice, and any attempt to force or deprive an individual of liberty is not only strictly prohibited but a matter that should be prevented at all costs. To uphold our commitment, we refuse to work with any suppliers who may specify money as a condition of employment. Suppliers must allow employees to freely serve notice and leave employment at their will, with a reasonable notice period.
Grayce has received no prior reports of modern slavery or human trafficking.
Grayce Group Limited is a management consultancy currently based in the UK. We operate in various sectors including but not limited to:
Based on the nature of our operations as a UK-based professional services business and our supplier profile, we consider the inherent risk of modern slavery within our own operations to be relatively low. However, we recognise that modern slavery can occur in any sector and geography, including within UK supply chains, and we remain vigilant.
Further information about Grayce’s business can be found on our website.
Grayce has various supply chains to ensure the effectiveness and efficiency of business operations. Within all supply chains, Grayce proactively strives to ensure suppliers adopt a consistent approach to modern slavery and trafficking and are low risk.
Grayce’s supply chain includes:
This is not an exhaustive list.
In general, Grayce’s supplier relationships are long-term and will continue if they add value to Grayce’s business operations and compliance. On occasion, some supplier relationships will be short-term and possibly one-off; these could be one-off catering & hospitality agencies, stationery or office equipment suppliers or some recruitment agencies.
All supplier relationships are critical to business operations at Grayce. At the time of publication, Grayce’s direct suppliers were predominantly based in the UK; we keep this position under review as our supplier base changes.
We are committed to acting ethically and with integrity in all our business relationships.
Grayce’s policies are managed centrally by the Human Resources team. They are developed by qualified business professionals who are experienced in their areas of expertise. Some policies are reviewed by external contractors, such as Grayce’s appointed qualified lawyers.
As part of our ongoing commitment to combating modern slavery and human trafficking, Grayce operates with the following policies in place:
All policies are available to all employees at any time. They can be accessed via our HR system, People+, independently and without prior permission. Grayce employees are obliged to comply with all policies. These policies set out our expectations for employees and suppliers.
Grayce reviews policies on a regular basis to ensure they are updated in line with legislative and best practice changes.
Suppliers are proactively made aware of our policies and adhere to the same high standards of operation, either through adopting Grayce’s policy requirements or by implementing their own policies which cover similar requirements.
At Grayce, we promote human rights. We have stringent due diligence procedures in place to enable us to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains. We aim to establish and assess areas of potential risk both within our business and supply chains.
Our due diligence procedures are outlined below.
Each employee of Grayce has a written contract of employment which includes a guarantee of pay and benefits, along with a reasonable period of notice, which enables them to resign and leave freely.
All employees have free, unlimited and anonymous access to mental health services. In addition, Grayce offers access to appointed and trained mental health first aiders at all times internally within Grayce.
We have a clear Whistleblowing Policy, which sets out the whistleblowing procedure. Whistleblowers are guaranteed protection from unfair or negative treatment as a result of taking action under this policy.
Contractors within Grayce’s supply chain are provided with appropriate terms within contractual documents, obliging suppliers and contractors to comply with the Modern Slavery Act and reserving the right for Grayce to audit suppliers and contractors where we consider it appropriate. Grayce does not manage our clients’ procurement or supplier payment transactions; our focus is on our own operations and supply chain.
We have key stakeholders who are allocated to manage client relationships and supplier relationships. The business relationships are reviewed on an ongoing basis, and commitments are clearly stated within the contracts. The key stakeholders are responsible for monitoring and enforcing the policy to clients, and are trained to raise any concerns to HR.
We have a number of ad-hoc suppliers, such as stationery, florists and catering, in which transactions are handled and will be reviewed on a case-by-case basis.
We do not currently use external specialist third parties to carry out modern slavery checks on specific suppliers or supply chains as a standard approach. Where a supplier or supply chain is identified as higher risk, we will consider enhanced due diligence measures proportionate to that risk.
Grayce’s operations are UK-based. However, some of our clients operate internationally, including in jurisdictions that may be considered higher risk for modern slavery and human trafficking. We recognise this may indirectly influence risk exposure for our people when working on client sites, and we encourage our employees to raise concerns through our internal reporting channels.
Potential risks include the use of third-party suppliers (including ad-hoc suppliers) and working in or with organisations operating across multiple sectors and geographies, where visibility of labour practices can vary.
Our suppliers are expected to have suitable modern slavery and human trafficking policies and processes in place within their own businesses and to cascade those policies to their own suppliers. Should suppliers fail to comply with our policies, we would immediately seek to terminate our relationship with that supplier.
Suppliers are required to report on any identified risks or concerns using the procedures outlined within their respective policies. If a process for reporting risks or concerns is not clearly outlined within supplier policies, Grayce expects that suppliers will follow Grayce’s reporting procedure.
If a supplier fails to meet desired standards in relation to modern slavery KPIs, this could result in a termination of the contract.
Grayce has implemented KPIs to measure the success of ensuring slavery and human trafficking are not taking place in any area of our business or supply chains. These are as follows:
We produce reports which allow Grayce to see which employees have successfully passed the modern slavery training. If employees have not completed this training, they will be given a strict deadline to complete the training. These reports are run on an annual basis to ensure that all employees are keeping up to date with compliance training. These reports are used for Grayce employees only.
The majority of employees at Grayce work on our clients’ sites and therefore can monitor working conditions. Those employees also keep in close contact with their managers within HQ, with whom they can raise any concerns.
Breaches or risks identified under this policy may result in disciplinary action under Grayce’s Disciplinary Policy.
We are committed to continuous improvement in this area.
Upon commencement of Grayce employment, all employees are signposted to our relevant and related policies to ensure they are aware of the risks of modern slavery and human trafficking both within our business and our supply chains.
Compliance training is conducted via an external provider using an online platform known as Atlas (previously iHasco). All employees are required to complete compliance training as part of their initial 90-day goals and must re-take training assessments on an annual basis. The training provided is aligned with Grayce’s stance on slavery and human trafficking, and completion is monitored on an ongoing basis. Training is available in different languages if necessary.
Employees are made aware of how to identify, report and escalate issues from the onboarding stages of employment.
This statement has been approved by the Board of Directors of Grayce Group Limited and is fully supported by all members of Grayce’s Executive Board and Leadership Team. We are committed to continuously reviewing policies, procedures, and practices internally and those of our suppliers. We endeavour to invest in training that is relevant to ensuring our entire workforce is aware of the steps required to prevent modern slavery and trafficking.
Signed: Â James Freeman, CFOÂ Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Dated: 22 April 2026
