Modern Slavery and Human Trafficking Statement

Qberry

Financial Year: 2025/26

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It sets out the steps Qberry has taken to prevent modern slavery and human trafficking within our business and supply chains, and reflects the standards expected of us as a supplier to UK public sector clients.

Although Qberry falls below the statutory turnover threshold (£36 million) that makes publication of this statement a legal requirement, we publish it voluntarily to support transparency with our public sector clients and partners, and to meet the supply chain due diligence expectations increasingly built into public sector procurement and bid requirements.

1. Organisation Structure, Business and Supply Chains

Qberry is a UK-based technology consultancy providing data, AI, and secure data environment services, predominantly to UK public sector clients including central government departments and agencies. Our work includes supporting secure data environments for sensitive datasets, AI and analytics capability, and procurement and delivery support on public sector technology programmes.

We operate primarily through direct employment and a small network of trusted associates and subcontractors, and engage cloud infrastructure providers, specialist technology suppliers, and professional services firms. We do not manufacture goods and hold no overseas manufacturing operations.

2. Policies

Qberry maintains a zero-tolerance approach to modern slavery and human trafficking, reflected in our:

  • Anti-Slavery and Human Trafficking Policy
  • Whistleblowing Policy, giving staff and associates a confidential route to raise concerns
  • Recruitment and Onboarding Policy, including right-to-work verification for all employees, associates, and subcontractors
  • Supplier and Subcontractor Code of Conduct, setting minimum ethical standards aligned with public sector expectations

3. Due Diligence Processes

Given the sensitivity of the environments we work in, including secure data environments handling sensitive public sector data, we apply due diligence proportionate to that context:

  • Vetting of all suppliers, subcontractors, and associates prior to engagement, including checks relevant to security clearance and public sector accreditation requirements where applicable
  • Anti-slavery clauses embedded in supplier, subcontractor, and associate contracts
  • Right-to-work verification for all individuals engaged by our business
  • Alignment with client-specific supply chain assurance requirements where these form part of contractual or bid obligations

4. Risk Assessment and Management

Qberry assesses its overall exposure to modern slavery risk as low, reflecting our direct-employment model, UK-based operations, and professional services nature of our work. The areas of relative (if limited) risk are:

  • Subcontractors and associates engaged on specific programmes or surge capacity
  • Lower-tier IT hardware and infrastructure suppliers
  • Recruitment channels used to source specialist or cleared personnel

We manage this by working with established, reputable suppliers and partners, applying contractual anti-slavery obligations, and reviewing supplier and associate relationships on an ongoing basis; particularly where engagements sit within secure or sensitive programmes.

5. Effectiveness — Key Performance Indicators

We measure effectiveness against:

  • Percentage of new suppliers, subcontractors, and associates screened prior to engagement
  • Number of concerns raised through whistleblowing channels and time to investigation/resolution
  • Percentage of relevant staff completing modern slavery awareness training annually
  • No confirmed instances of modern slavery identified within our business or supply chain during the reporting period

6. Training and Capacity Building

Staff and associates involved in recruitment, procurement, or client delivery receive training covering:

  • Recognising the indicators of modern slavery and human trafficking
  • Escalation routes for raising concerns
  • Refresher training on a periodic basis, particularly for those involved in supplier or associate engagement on public sector programmes

Approval

This statement was approved by Tom Fitzherbert of Qberry on 30 October 2025 and will be reviewed annually, or in line with client requirements.

Tom Fitzherbert, Director

Qberry