Wovex Modern Slavery and Human Trafficking Statement

For the financial year ending 30 June 2025

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out the steps Wovex (“we”, “us”, “our”) has taken, and is taking, to prevent modern slavery and human trafficking in our business and supply chains.

This statement covers Wovex Limited, a private limited company incorporated in England and Wales.

We recognise that modern slavery is a global issue and includes slavery, servitude, forced or compulsory labour, and human trafficking. We are committed to conducting our business in a way that respects human rights and to reducing the risk of modern slavery within our operations and supply chains.

1. Our organisation, structure, business and supply chains

Wovex Limited is a UK‑headquartered software and services company, founded in 2013, providing benefits realisation and manage‑through‑value software to organisations around the world.

Our platform enables customers (including public sector bodies and private enterprises) to map, track and report on the value delivered by their projects and investments, supported by professional services such as onboarding, configuration and training.

Corporate structure

  • Wovex Limited is incorporated in England and Wales as a private limited company (company number 08553412).

  • The company’s registered office is in Cambridgeshire, United Kingdom.

  • Wovex supports customers globally and may operate through local registrations or partners in other jurisdictions, including (for example) Australia and New Zealand and other markets through partner arrangements.

Our operations

Our direct operations are primarily:

  • product design, development and testing of Wovex’s software platform

  • sales, marketing and customer success

  • professional and technical services (including onboarding, configuration, training and advisory services)

These activities are carried out by a team of skilled employees and contractors, working primarily in professional office environments or remotely.

Our supply chains

As a software‑led business, our supply chains are relatively simple and consist mainly of:

  • cloud hosting, data storage and other IT infrastructure providers

  • software vendors and SaaS providers we use internally (e.g. collaboration, CRM, finance, HR and support tools)

  • professional service providers (e.g. legal, accounting, HR, marketing and consultancy)

  • office facilities, coworking spaces and associated services (e.g. cleaning, security and maintenance)

  • hardware, telecoms and other equipment suppliers (e.g. laptops, networking, mobile devices)

We recognise that the highest risk of modern slavery in our supply chain is likely to be in indirect tiers – for example, in the manufacturing of IT hardware, data centre operations, facilities management, and in lower‑paid or casual labour used by some suppliers and landlords.

2. Our policies in relation to slavery and human trafficking

Our approach to modern slavery is grounded in Wovex’s values, including being a force for good, being a good human and empowering others.These values shape how we work internally and with our customers, partners and suppliers.

Key policies (existing or to be finalised and adopted during the relevant financial year) include:

  • Modern Slavery and Human Trafficking Policy
    Sets out Wovex’s zero‑tolerance stance on modern slavery and human trafficking and explains how suspected instances can be reported and will be handled.

  • Code of Conduct / Ethics Policy
    Defines expected behaviours for all Wovex employees, contractors and directors, including respect for human rights, fair treatment, and compliance with applicable labour laws.

  • Supplier Code of Conduct

Communicates our expectations that suppliers:

    • prohibit forced, bonded or involuntary labour
    • prohibit human trafficking and child labour
    • provide safe and fair working conditions, including lawful wages and working hours
    • allow freedom of movement and do not retain identity documents
    • respect workers’ rights to freedom of association and collective bargaining
    • cascade these expectations into their own supply chains.

Recruitment and Selection Policy
Ensures that recruitment is transparent and based on merit, that no recruitment fees are charged to candidates, and that all workers have the right to work and enter employment freely.

Whistleblowing / Speak‑Up Policy
Provides a safe and confidential mechanism for employees, contractors, and others to raise concerns (including those related to modern slavery and human rights) without fear of retaliation.

These policies are, or will be, made available to relevant staff and, where appropriate, to suppliers. They are reviewed periodically and updated as needed.

3. Due diligence in relation to modern slavery

We are developing and strengthening proportionate due diligence processes to identify, assess and mitigate the risk of modern slavery in our business and supply chains. These processes focus on higher‑risk areas and suppliers.

New suppliers

For new strategic or higher‑risk suppliers (for example, key cloud hosting providers, facilities management, or hardware suppliers), we aim to:

  • Assess the overall risk profile, including country, sector and type of service

  • Review the supplier’s own modern slavery or human rights statement and policies (where applicable)

  • Request confirmation that they comply with all relevant labour and human rights laws

  • include contractual obligations related to modern slavery, human rights and labour standards, where appropriate.

Existing suppliers

For existing key suppliers, we intend to:

  • Periodically review whether they have published modern slavery statements (if in scope of local legislation)

  • Refresh due diligence on a risk‑based cycle

  • Seek clarifications, improvements, or alternative arrangements where performance falls short of our expectations.

Internal practices

Within our own operations, our due diligence includes:

  • Verifying employees’ right to work in the relevant jurisdiction

  • Issuing clear written contracts outlining voluntary employment and key terms (wages, hours, benefits, notice periods)

  • Paying wages directly to employees into bank accounts, where possible

  • Avoiding recruitment practices that could create debt bondage or unsafe working arrangements.

4. Risk areas and how we manage them

We recognise that the risk of modern slavery is not static and can arise or change as our business and supply chains evolve. While our direct operations (professional and knowledge‑based work in the UK and similar jurisdictions) are assessed as relatively low risk, we have identified several areas where the risk is higher:

  1. IT hardware manufacturing and electronics supply chains

    • Risk of forced or child labour in raw material extraction and component manufacturing.

    • Our response: prioritising reputable suppliers with robust human rights policies, seeking information on their supply chain practices and certifications, and consolidating spend with suppliers who demonstrate strong standards.

  2. Cloud and data centre operations

    • Risk of poor labour practices in some facilities and contracted labour.

    • Our response: partnering with established providers that have published modern slavery statements, clear human rights commitments and recognised compliance certifications where appropriate.

  3. Facilities management, cleaning and other low‑wage services

    • Risk of exploitation among lower‑paid, migrant or agency workers.

    • Our response: seeking assurance from landlords and facilities providers that they apply appropriate checks and standards to their own contractors and sub‑contractors.

  4. Offshore or subcontracted services (if used)

    • Risk of inadequate labour standards, particularly in higher‑risk jurisdictions.

    • Our response: conducting additional due diligence where services are delivered from higher‑risk countries, using contractual protections, and preferring suppliers with clear, published commitments and track records.

Risk management steps

To manage these risks, we are:

  • Mapping our key suppliers, grouped by category and risk level

  • Focusing enhanced due diligence on higher‑risk supplier categories

  • Building modern slavery considerations into procurement and vendor review processes

  • Setting escalation routes where concerns are identified, including the possibility of exiting relationships where issues cannot be satisfactorily resolved.

5. Measuring our effectiveness

We are at an early but developing stage in formalising how we measure the effectiveness of our actions to prevent modern slavery. Over the course of the relevant financial year and beyond, we intend to track and report against a small number of practical performance indicators, such as:

  • Supplier coverage

    • % of strategic/high-risk suppliers that:

      • have been risk‑assessed for modern slavery; and

      • have accepted our Supplier Code of Conduct or provide an equivalent level of protection.

  • Policy adoption

    • Completion and approval of a formal Modern Slavery and Human Trafficking Policy and Supplier Code of Conduct.

    • % of employees who have acknowledged our Code of Conduct and relevant policies.

  • Training

    • % of employees in targeted functions (e.g. procurement, leadership, HR, customer‑facing teams) who have completed modern slavery awareness training.

  • Incidents and remediation

    • Number of concerns or incidents raised related to modern slavery or human rights.

    • Time taken to investigate and resolve any such concerns.

    • Actions taken to remedy issues and prevent recurrence.

Our aim is continuous improvement: over time, we will refine these indicators, set realistic targets, and report on our progress in future statements.

6. Training and capacity building

We recognise that awareness and understanding among our people are critical to identifying and managing modern slavery risks.

We therefore intend to implement and maintain the following measures:

  • Induction training
    Introduction to Wovex’s values, Code of Conduct, and our expectations regarding ethical behaviour, human rights and modern slavery for all new starters.

  • Role‑specific training
    Additional training for employees whose roles may more directly influence or encounter modern slavery risks, including:

    • Procurement and vendor‑management staff

    • Leadership team members involved in strategic supplier decisions

    • HR and recruitment staff,

    • Customer‑facing teams who may need to respond to customers’ modern slavery and ESG enquiries.

  • Periodic refreshers
    Short refresher modules and communications to maintain awareness of modern slavery issues, emerging risks and reporting channels.

  • Access to guidance
    Easy access to internal policies and practical guidance on what signs to look for and how to escalate concerns safely.

7. Looking ahead

Over the next reporting period, Wovex intends to:

  • Formalise and approve our Modern Slavery and Human Trafficking Policy and Supplier Code of Conduct

  • Complete a mapping and risk assessment of key suppliers, focusing on higher‑risk categories

  • Roll out initial modern slavery awareness training to relevant employees

  • Embed modern slavery checks into supplier onboarding and renewal processes

  • Review this statement annually and update it to reflect progress and any significant changes in our business or supply chain.

8. Approval and signature

This statement has been approved by the Board of Directors of Wovex Limited for and on behalf of Wovex and any other entities listed in Appendix 1.

Signed: Trevor Howes

Title: Chief Executive Officer

30th June 2025

Appendix 1 – Entities covered by this statement

This statement applies to the following organisations within the Wovex Group that fall within the scope of section 54 of the Modern Slavery Act 2015, and their supply chains:

  1. Wovex Limited (company number 08553412), incorporated in England and Wales.

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