Modern Slavery Statement

Objective

Aptitude Advisors and/or its subsidiaries and affiliated entities worldwide (collectively, “Aptitude Global” or “the Company”) sets out and actions against the potential modern slavery risks.  It puts in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during our ongoing trading and current financial year.

This policy also provides guidance to Aptitude individuals worldwide whether employed directly, indirectly as contractors or otherwise (collectively referred to as “Employees”, employees, “You” or “you” in this Policy) in understanding our protocols in respect of its obligations.  

Introduction

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the ‘Act’) and constitutes our business’ slavery, child labour and human trafficking statement for the financial year end 31 March 2025.

Our Business

We are a specialist Data Solutions provider with innovation and automation at our core. We apply a 'Business First' approach to solving complex Data problems for our clients across Regulated industries - financial services, legal, pharma, and energy.

We are a small organisation, based primarily in Spain, Portugal and the United Kingdom and each employee works remotely. We believe that the risk of human trafficking in our workforce is very low. The majority of our team members are trained professionals who have all been selected through a transparent and rigorous hiring process. Aptitude Global has examined the risk of modern slavery within its business operations on a risk-based approach and considers the risks of modern slavery to be very low. The assessment is based upon the nature of our business and the services we provide to customers which present very limited exposure to modern slavery risks.

Our Supply Chains

Our supply chain includes IT consultants, recruitment agencies, marketing services, legal and insurance advisers, training providers and criminal and financial screening agents. As a professional services company, our business model does not carry with it a high level of slavery risk compared to businesses operating in other sectors. Nevertheless, this statement covers those areas within our business supply chain which we have identified as presenting a potential slavery risk. We continue to focus on these areas to ensure we mitigate any associated risks to a reasonable level.

We have zero tolerance to slavery and human trafficking and expect those in our supply chain and contractors to comply with our policies, procedures, and values.

We carry out due diligence on all of our major supply chain partners and take steps to ensure their compliance with the Act.

There were no instances of slavery or human trafficking concerns raised to us during the financial year ending on 31 March 2025, or any years prior to the date of our company registration in 2014.

Our Policies on Slavery & Human Trafficking

Aptitude Global is absolutely committed to preventing modern slavery or human trafficking throughout its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Our Policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We have the following policies which incorporate ethical standards for staff and our workers:

• Anti-Corruption and Bribery Policy
• Anti-Money Laundering policy
• Whistleblowing Policy and Procedure

Compliance

In addition to a risk assessment and as part of our commitment to preventing modern slavery and human trafficking in our business, we continue to ensure our compliance with the Act by:

• Driving awareness of our company policies which outlines our requirements under the Modern Slavery Act;
• Where appropriate and according to the level of potential risk, introducing contractual provisions in supplier contracts that require suppliers to comply with applicable anti-slavery and anti-trafficking laws; and
• Maintaining a risk-based assessment of suppliers in order to identify any modern slavery or human trafficking related risks.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff and contractors.

Disclaimer – The company reserves the right to alter, append or withdraw this policy either in part or in full based on management’s discretion.

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Next review: 31 December 2026