In accordance with s.54 Modern Slavery Act 2015
Coverage
This statement covers all companies within the “Qodea” group, including the ultimate parent company Ruby Topco Limited, and the “Qodea” and “TMC3” brands. A full list of all group companies covered by this policy is available on request.
Introduction from the Chief Financial Officer
It continues to be a priority for Qodea to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This statement highlights the key activities we have undertaken during this financial year to combat modern slavery in our organisation and supply chain, including:
The development and enforcement of a supplier code of conduct that provides a structure for our supplier due diligence and explicitly prohibits modern slavery and outlines expectations for ethical labour practices.
Providing training to employees, especially those involved in procurement and supply chain management, to recognise the signs of modern slavery and report suspicions. Publishing an annual modern slavery statement that outlines the steps taken to address modern slavery risks and ensure compliance with relevant regulations
Organisational structure
We are a provider of cloud computing services and software to businesses across the UK, Europe and beyond. Our ultimate parent company is Ruby Topco Limited, which has its head office in the United Kingdom. We have over 300 employees worldwide and operate in Europe and North America. Qodea has a global annual turnover in excess of £90m.
Our Approach
We have a zero-tolerance approach to modern slavery and human trafficking and we are committed to implementing and enforcing effective due diligence systems and controls to ensure modern slavery is not taking place anywhere in our business or within our supply chain.
Prior to entering into business relationships with customers or suppliers, we undertake due diligence in order to identify any potential legal, regulatory and/or reputational risks. We proactively monitor and manage these relationships to understand the risks faced by our customers and suppliers and our ability to work with them and to support them. Third party services and goods procured are the result of transparent, objective, risk-based decision making processes that are compliant with all applicable laws and regulations. Being a responsible business is fundamental to the way we behave, and we have developed a cohesive and interconnected strategy to help us achieve and deliver on our commitments.
Our Policies and Supplier Code of Conduct
We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.
Our Risk Assessment
Our business-wide risk assessment reflects the policies, controls and procedures we have in place to mitigate modern slavery risks. This is reviewed and, where appropriate, updated annually or more frequently in the event of a significant structural or any other major change that could influence the risk to our business.
Our supply chains include, and are primarily concerned with, the provision of services ancillary to cloud computing, such as data security, information management and software licensing. The risk of modern slavery and human trafficking occurring within our business and supply chain remains low and we have adequate controls in place to manage, monitor and mitigate such risks.
Measuring Effectiveness
In the last 12 months, we had no reported incidents of slavery or trafficking in our supply chain.
Our staff have successfully completed a modern slavery and human trafficking e-learning course;
New trade suppliers to our business have been subject to our new supplier code of conduct
Looking to the year ahead, we are committed to ensuring that we continue to ensure staff are trained appropriately, all suppliers are evaluated against our supplier code of conduct and we continue to remain vigilant in our dealing with others.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group's slavery and human trafficking statement for the current financial year. It was approved by the board in May 2025.
Signed by Bill Bates, Director
Last updated: May 2025