Modern Slavery Act

Modern Slavery and Human Trafficking Statement

Financial Year Ending 5 April 2025

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the steps taken by Novatus Global Ltd (“Novatus”) during the financial year ending 05 April 2025 to prevent modern slavery and human trafficking within our business operations and supply chains.

Our Organisation

Novatus Global Ltd is a management consultancy providing advisory and delivery services to organisations within the financial services sector. The company operates globally from its London headquarters and delivers services through a combination of employees, associates, and specialist third-party suppliers.
We recognise that modern slavery, forced labour, servitude, and human trafficking remain global risks across industries and supply chains. Although the nature of professional services presents a comparatively low inherent risk, Novatus maintains a zero-tolerance approach to modern slavery and is committed to conducting business ethically, transparently, and responsibly.

Governance and Responsibility

Responsibility for modern slavery risk management sits with senior leadership and is overseen by the Board of Directors.
Key governance measures include:
• Board approval of this annual statement
• Oversight of ethical business practices through company policies and internal controls
• Integration of modern slavery considerations into supplier onboarding and procurement activities
• Periodic review of policies aligned to legal and regulatory expectations

Policies and Ethical Framework

Novatus maintains policies designed to prevent exploitation and promote responsible business conduct, including:
• Code of Conduct
• Anti-Bribery and Corruption Policy
• Equal Opportunities and Anti-Harassment Policies
• Whistleblowing Policy
• Supplier Engagement and Procurement Standards
These policies require employees, contractors, and suppliers to operate lawfully, ethically, and with respect for human rights.
Our corporate values – collaboration, sustainability, client focus, quality, trust, and innovation – underpin our commitment to responsible employment practices and socially sustainable operations.

Our Supply Chains

Our supply chain primarily consists of:
• Professional services and consultancy partners
• Recruitment and staffing agencies
• Technology and software providers
• Office and operational service suppliers
While assessed as generally low risk, Novatus recognises that labour exploitation risks may arise indirectly through recruitment channels or outsourced services.

Due Diligence Processes

During the reporting period, Novatus continued to strengthen due diligence controls to mitigate modern slavery risks.
Our approach includes:
• Risk-based supplier onboarding assessments
• Use of reputable recruitment agencies subject to contractual compliance requirements
• Inclusion of modern slavery and ethical conduct expectations within supplier agreements where appropriate
• Review of supplier relationships during procurement and renewal cycles
• Preference for suppliers demonstrating responsible labour and employment practices
Suppliers identified as higher risk may be subject to enhanced review prior to engagement.

Employment Practices

Novatus is committed to fair and lawful employment practices.
We:
• Verify all employees’ right to work in accordance with UK legislation
• Provide employment contracts compliant with applicable labour laws
• Offer competitive compensation and benefits aligned with industry benchmarks
• Maintain a workplace free from discrimination, coercion, harassment, or victimisation
• Conduct periodic reviews of remuneration and working conditions
We promote diversity, inclusion, and equal opportunity across our workforce and continue to monitor gender diversity and broader workforce representation metrics.

Training and Awareness

To support prevention efforts, Novatus promotes awareness of ethical conduct and modern slavery risks through:
• Employee onboarding covering ethical expectations and reporting channels
• Management awareness of supplier and recruitment-related risks
• Communication of whistleblowing protections and escalation routes
Training and awareness activities will continue to evolve proportionately to organisational risk exposure.

Reporting Concerns and Whistleblowing

Novatus encourages employees, contractors, and partners to report concerns regarding unethical behaviour or potential human rights abuses.
Reports may be raised through established internal reporting channels without fear of retaliation. All concerns are reviewed appropriately and investigated where required.

Assessing Effectiveness

Novatus monitors the effectiveness of its modern slavery controls through:
• Annual review of policies and governance arrangements
• Ongoing supplier oversight during engagement lifecycle
• Monitoring of reported concerns via whistleblowing mechanisms
• Periodic reassessment of organisational and supply-chain risk exposure
No instances of modern slavery or human trafficking were identified within our operations during the reporting period.

Future Commitments

Over the next financial year, Novatus intends to:
• Further formalise supplier risk classification processes
• Expand contractual modern slavery provisions where proportionate
• Enhance internal awareness of responsible procurement practices
• Continue reviewing policies in line with evolving regulatory expectations and industry best practice

Approval

This statement has been approved by the Board of Directors of Novatus Global Ltd and signed on its behalf.
Approved by the Board: 21 April 2025
Signed:
Matthew Ranson
Company Director
Novatus Global Ltd

Novatus Global Ltd will review and publish an updated Modern Slavery and Human Trafficking Statement annually in accordance with Section 54 of the Modern Slavery Act 2015.

‍