Ethical Business, Modern Slavery & Responsible Sourcing Policy

Last Reviewed: January 2026
Applies to: Ibexstone Ltd, its directors, employees, contractors, suppliers, and partners

1. Purpose & Commitment

Ibexstone Ltd is committed to conducting business ethically, responsibly, and in compliance with applicable laws and recognised international standards. We oppose all forms of modern slavery, forced labour, and human trafficking and are committed to responsible sourcing, delivery, and workforce practices across our operations and supply chains.

This policy supports our management system principles aligned to ISO 9001 (Quality Management), ISO/IEC 27001 (Information Security), and ISO/IEC 42001 (AI Management Systems), including leadership accountability, risk‑based thinking, and continual improvement.

2. Legal & Regulatory Context

Ibexstone Ltd provides consultancy, software and AI development, and talent services. Our current annual turnover is below the £36 million threshold defined in section 54 of the UK Modern Slavery Act 2015, and we are therefore not legally required to publish a formal Modern Slavery Statement.

Notwithstanding this, we voluntarily apply proportionate controls consistent with the principles of the Act and public‑sector expectations.

3. Operations & Supply Chain

Ibexstone Ltd operates primarily in the United Kingdom, with it’s service desk and development team in Islamabad, Pakistan. Our supply chain primarily includes professional services providers, technology vendors, contractors, and talent partners.

We recognise that offshore delivery and subcontracted services may present increased risk and manage these appropriately.

4. Risk‑Based Approach & Due Diligence

In line with ISO management system principles, we apply a risk‑based and proportionate approach to ethical sourcing and modern slavery prevention, which includes:

• Assessing supplier risk based on geography, service type, and labour practices
• Requiring suppliers and subcontractors to comply with applicable employment and labour laws
• Embedding contractual clauses prohibiting modern slavery and mandating disclosure of breaches
• Reserving the right to suspend or terminate relationships where serious concerns arise

Due diligence activities are scaled to the size, nature, and risk profile of the engagement.

5. Roles, Awareness & Reporting

Overall accountability for this policy rests with the Directors of Ibexstone Ltd. Management is responsible for implementation and monitoring.

Relevant staff are made aware of modern slavery indicators and ethical expectations appropriate to their role. Anyone working for, or on behalf of, Ibexstone Ltd is encouraged to report concerns confidentially via:

compliance@ibexstone.com

All reports are handled sensitively, investigated promptly, and without retaliation.

6. Monitoring & Continuous Improvement

This policy is reviewed at least annually and updated as the organisation grows, including if Ibexstone Ltd becomes subject to formal reporting obligations under section 54 of the Modern Slavery Act 2015. Continuous improvement actions are informed by risk reviews, supplier feedback, and business changes.

7. Approval

Approved by the Board of Directors of Ibexstone Ltd.

Approval Date: January 2026