Xonetic Modern Slavery Policy

Effective date: 16 January 2026

Introduction

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Xonetic Limited (‘Xonetic’) has a zero-tolerance approach to modern slavery and strives to maintain our commitment to combatting and ending modern slavery in all of its forms. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chains. As a responsible and ethical business and employer, no employee of Xonetic is paid less than the national minimum wage and all our employees over the age of 23 are paid at least the national living wage, in accordance with applicable laws.

1.1 Our High-Risk Areas

Xonetic Limited (‘Xonetic’) is a privately held UK based limited company specialising in management consulting with a focus on CIO/COO Advisory. Xonetic has a small number of employees whom are highly skilled and therefore not typically at risk from modern slavery. Although we have a low risk of modern slavery infringements within our business, this does not distract from our commitment to ethical practices, including our modern slavery obligations.

Our main risk area is our client base, some of whom employ large numbers of people across many countries.

In order to mitigate this risk – we identify customers who are below the £36 million turnover threshold for mandatory reporting, and review their approach to Modern Slavery, during the contracting process.

1.2 Our Suppliers

Xonetic operates a supplier policy, and control of any new suppliers is managed by the Managing Director. We engage directly or via reputable agencies with each of our suppliers and conduct due diligence on all suppliers before allowing them to become a supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery.

We also mitigate this risk by using large suppliers (over the £36m threshold) who have active policies in place to manage modern slavery.

1.3 Training and awareness of our statement

Xonetic includes our modern slavery statement within our employment handbook, which all staff are required to review on commencing employment. Currently we do not operate an ongoing refresh program since the risk of modern slavery occurring in our business remains low.

Where our client work covers areas that could potentially have modern slavery ramifications, such as sourcing new suppliers on behalf of our clients, we ensure that our work is peer reviewed, including ethical review by a Senior Manager or Director.

This statement is available on our website – www.xonetic.com/modern-slavery-policy

Governance and review

The Managing Director is responsible for overseeing compliance with this policy. It is reviewed annually and updated where necessary to reflect changes in legislation, business activity or identified risks.