Slavery and Human Trafficking statement

Organisation structure 

This statement comprises the Slavery and Human Trafficking statement of Gravita Business Services II Limited (“Gravita”), its subsidiaries and parent company (together “Gravita” or the “Group”) for the fiscal year 2024/25 and the financial year ending 30 April 2026, in accordance with section 54(1) of the Modern Slavery Act 2015 (“MSA”). 

Our Business  

Gravita delivers a comprehensive range of accounting and professional finance services to institutional clients and entrepreneurs across the UK and further afield globally. The nature of our operations characterised by skilled professional workforces, regulated environments, and UK‑based service delivery places the organisation at a comparatively low risk of exposure to modern slavery or human trafficking. 

Nevertheless, Gravita recognises that low inherent risk does not equate to no risk. The Group remains fully committed to upholding the highest ethical, legal, and professional standards. We adopt a strict and unwavering zero‑tolerance stance toward all forms of modern slavery, human trafficking, forced labour, and labour exploitation within our operations and throughout our supply chain. 

This commitment is embedded in our governance framework, our policies, and our culture. We expect every employee, supplier, and business partner to adhere to these standards, and we actively monitor compliance across all areas of the business. By maintaining robust due‑diligence processes, clear reporting mechanisms, and continuous staff training, Gravita ensures that risks however small are proactively identified, assessed, and addressed. 

Our approach reflects not only our legal obligations under the Modern Slavery Act 2015, but also our broader responsibility to protect the dignity, rights, and wellbeing of every individual connected to our business. Gravita remains dedicated to fostering an environment where exploitation is neither tolerated nor overlooked, and where ethical conduct is integral to the way we operate every day. 

Principles, Values, and Culture 

At Gravita, transparency is fundamental to how we operate and to the trust placed in us by our clients, our people, and the wider accountancy profession. We uphold this commitment by grounding our work in a clear set of Values that serve as the foundation of our organisation. These Values shape the way we conduct ourselves, inform the decisions we make, influence the relationships we foster, and underpin the culture we continue to build. 

We are ambitious 

Determined and armed with a can-do attitude, we aim to achieve big things. We innovate, challenge the status quo and champion forward-thinking. 

We value relationships 

People are the core of our business. We build relationships rooted in integrity, commitment and trust to strengthen our sense of community. 

We care deeply 

We are brimming with expertise and always eager to do our best work. We balance this by ensuring we are conscientious, considerate and empathetic to our colleagues and clients alike. 

We communicate clearly 

Communicating with respect and positivity is paramount. We encourage expectations to be clearly outlined and feedback to be constructive and actionable so we’re all on the same page 

Policies in relation to Slavery and Human Trafficking 

Gravita recognises the critical role it plays alongside its suppliers, partners, and wider stakeholders in addressing the ongoing and evolving risks associated with modern slavery and human trafficking. We understand that preventing exploitation requires collective vigilance, ethical leadership, and a consistent commitment to responsible business practices across all areas of our operations and supply chain. 

To uphold these standards, Gravita has implemented a comprehensive framework of practices, procedures, and policies designed to ensure full compliance with UK employment legislation, human rights obligations, and international best practice expectations. These measures support a safe, respectful, and transparent working environment and reinforce our zero tolerance approach to any form of exploitation. 

Key internal policies and supporting procedures include: 

• Diversity, Equity and Inclusion Policy, incorporating our Equal Opportunities Statement, which ensures fair and equitable treatment for all individuals working with or on behalf of Gravita. 

• Whistleblowing Policy, providing a confidential and accessible mechanism for reporting concerns, including potential indicators of modern slavery or unethical conduct. 

• Health and Safety Policy, safeguarding the wellbeing of employees, contractors, and visitors, and ensuring safe working conditions throughout our operations. 

• Grievance Procedures, enabling employees to raise concerns formally and ensuring all issues are addressed promptly, transparently, and in line with our legal obligations. 

Collectively, these policies establish a strong governance foundation that supports our commitment to ethical practice and responsible supply chain management. They also reinforce Gravita’s expectation that every individual and organisation connected to our business upholds the same high standards of integrity, respect, and accountability. 

Supplier Due Diligence and Risk Assessment 

Gravita requires all suppliers, without exception, to confirm full compliance with all applicable anti‑slavery and human‑trafficking legislation, including the Modern Slavery Act 2015. As part of our commitment to responsible supply‑chain management, we expect suppliers not only to meet legal requirements but to demonstrate proactive and transparent ethical practices. This includes maintaining their own Modern Slavery or Human Rights Policy that clearly outlines the measures they take to identify, assess, mitigate, and prevent the risk of forced labour or human trafficking within their operations and throughout their supply chains. 

The majority of Gravita’s suppliers operate within the UK, a jurisdiction where the overall risk of modern slavery is considered low due to established regulatory frameworks, robust labour protections, and higher levels of corporate governance. However, Gravita recognises that risks can still arise particularly where suppliers engage subcontractors, rely on temporary labour, or operate in sectors with known vulnerabilities. 

For suppliers located in, or connected to, higher‑risk geographies or industries, Gravita imposes enhanced requirements. These include stringent contractual obligations mandating compliance with all relevant anti‑slavery laws, the implementation of appropriate due‑diligence processes, and clear expectations regarding transparency over labour practices. These obligations are embedded within our supplier contracts and reinforced through our Supplier Code of Conduct. 

We apply robust and risk‑based controls across our entire supplier network covering services such as cleaning, facilities management, recruitment, legal support, design, marketing, consultancy, and IT services. Our procurement and compliance teams carry out due‑diligence checks during onboarding, and anti‑slavery compliance is further reviewed at contract renewal or when a material change occurs in the supplier’s structure or service delivery model. Additional scrutiny is applied to suppliers operating in higher‑risk categories or where concerns have been raised. 

Gravita maintains a strict zero‑tolerance stance on non‑compliance. Suppliers that fail to meet our standards whether through inadequate controls, refusal to provide required documentation, or evidence of actual or suspected labour exploitation are not engaged. If concerns arise during an existing relationship, the supplier may be subject to corrective‑action requirements, suspension, or immediate contract termination where appropriate. 

Through these measures, Gravita ensures that our suppliers uphold the same ethical principles and high standards that we expect across our organisation and that modern slavery has no place in any part of our value chain. 

Training 

Gravita is committed to ensuring that all employees have a clear understanding of modern slavery risks and their responsibilities in preventing exploitation. To support this, every member of staff is required to complete mandatory Modern Slavery and Human Trafficking training as part of their induction and on an annual refresher basis. This training is designed to equip our people with the knowledge needed to recognise early indicators of modern slavery, understand how such risks may arise within our supplier base, client engagements, or other third‑party interactions, and respond appropriately where concerns are identified. 

The training covers key topics such as: 

• Recognising warning signs of forced labour, human trafficking, and exploitation 

• Understanding risk factors across different industries, regions, and supply‑chain tiers 

• Supplier and client‑related vulnerabilities, including subcontracting, recruitment practices, and temporary labour arrangements 

• Reporting and escalation procedures, ensuring employees know how to raise concerns confidentially and without fear of reprisal 

• Gravita’s zero‑tolerance culture, legal obligations, and expectations of ethical conduct 

Additional enhanced training is provided to employees in higher‑risk roles, including Procurement, HR, Operations, and client‑facing teams who may be more exposed to potential indicators of exploitation. These sessions include deeper due‑diligence guidance, practical case studies, and scenario‑based learning to strengthen awareness and informed decision‑making. 

By ensuring comprehensive and consistent training across the Group, Gravita reinforces its commitment to fostering a well‑informed workforce, capable of identifying, preventing, and escalating concerns relating to modern slavery. This is a core element of our broader approach to safeguarding human rights and maintaining ethical, responsible business practices across all areas of our operations. 

Reporting 

In addition to raising concerns directly with a manager or a member of the leadership team, all colleagues have access to Gravita’s formal whistleblowing procedure, which enables them to report any issues including suspected instances of modern slavery or human trafficking confidentially and, if preferred, anonymously. Our whistleblowing framework is supported and reinforced by our Ethics & Independence Policy, which sets clear expectations for professional conduct, integrity, and ethical behaviour. This policy provides further guidance on how concerns should be reported, the protections afforded to individuals who speak up, and the standards of independence and objectivity that underpin our culture of transparency. 

Together, the Whistleblowing Procedure and the Ethics & Independence Policy ensure that employees, contractors, and other stakeholders can raise potential modern slavery concerns without fear of retaliation, knowing that all reports will be taken seriously, investigated promptly, and managed in accordance with our zero‑tolerance approach to unethical or unlawful practices. These mechanisms form a core part of Gravita’s commitment to maintaining a responsible, safe, and ethically governed work environment. 

Commitment 

Gravita remains firmly committed to playing its part in the global effort to eradicate modern slavery and human trafficking. Our responsibility extends beyond compliance: it reflects our ethical duty to safeguard the dignity and rights of every individual connected to our organisation. We recognise that meaningful progress requires ongoing vigilance, collaboration, and continual improvement. 

We will continue to strengthen our internal practices, enhance our supply‑chain oversight, and work proactively with suppliers, clients, and partners to ensure that exploitation has no place in our business or the professional services environment more broadly. Our commitment also reaches into the wider communities in which we operate, where we aim to contribute positively by raising awareness, supporting responsible business practices, and championing human rights standards across our industry. 

Through sustained action, transparent governance, and a zero‑tolerance approach to any form of modern slavery or human exploitation, Gravita will continue to uphold the highest ethical standards and remain a responsible, accountable, and socially conscious organisation. 

Signed for on behalf of Gravita: Ian Cokayne, Board Member and Chief Legal and Risk Officer 

Approved February 2026