Introduction

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that Initia Systems Limited ("Initia Risk", "we", "our", or "us") has taken during the financial year to ensure that slavery and human trafficking is not taking place in our business operations or supply chains.

Initia Systems Limited is incorporated in England and Wales (company number 15403848) with its principal office at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom.

Our Business

Initia Risk is a software-as-a-service (SaaS) provider of governance, risk, and compliance (GRC) solutions. We provide cloud-based risk management, compliance tracking, and audit preparation tools to organisations primarily in the United Kingdom and Europe.

Our business model is primarily digital, with operations focused on software development, customer support, and professional services. We operate with a relatively small, directly-employed workforce and limited physical supply chains.

Our Supply Chains

Our supply chains are limited and primarily consist of:

Cloud infrastructure and hosting services (AWS, Azure, or similar providers)
Software development tools and third-party software licenses
Professional services (legal, accounting, consulting)
Office facilities and equipment (where applicable)
Marketing and business development services

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our commitment is reflected in:

Our Code of Conduct, which sets out the expected standards of behaviour for all employees and contractors
Our Supplier Code of Conduct, which requires suppliers to comply with all applicable laws, including those relating to modern slavery and human trafficking
Our recruitment policies, which ensure that all employees have the right to work in the UK and are employed in accordance with UK employment law
Our commitment to fair pay and working conditions for all employees

Due Diligence Processes

To identify and mitigate the risk of modern slavery and human trafficking in our business and supply chains, we:

Conduct due diligence on new suppliers before entering into contracts
Review our existing suppliers on a regular basis
Prefer to work with suppliers who have their own modern slavery statements or demonstrate commitment to ethical practices
Use established, reputable cloud service providers with strong ethical and compliance frameworks
Maintain direct employment relationships with our workforce, avoiding the use of labour providers or intermediaries where possible

Risk Assessment

Given the nature of our business as a SaaS provider with a primarily digital supply chain and directly-employed workforce, we assess our risk of exposure to modern slavery and human trafficking as low. However, we remain vigilant and committed to:

Regularly reviewing our supply chains for any changes that might increase risk
Staying informed about modern slavery risks in the technology sector
Taking appropriate action if any concerns are identified

Training

We provide training to relevant staff members on identifying and reporting concerns related to modern slavery and human trafficking. This training is incorporated into our broader compliance and ethics training programme.

Effectiveness and Future Steps

We will continue to review and enhance our policies and procedures to ensure they remain effective in preventing modern slavery and human trafficking. In the coming year, we plan to:

Continue to monitor our supply chains and assess risks
Enhance our supplier due diligence processes
Provide ongoing training to staff on modern slavery awareness
Review and update this statement annually

Approval

This statement has been approved by the board of directors of Initia Systems Limited and will be reviewed and updated annually.

Signed on behalf of Initia Systems Limited
Board of Directors
January 2025

Modern Slavery and Human Trafficking Statement