Modern Anti-Slavery Policy

Company Name: Heads Up Limited
Company Registration Number: 8541858

Policy Owner: Sonia Gill
Effective Date: 2nd March 2026

1. Policy Statement

Heads Up Limited is committed to conducting business ethically and with integrity. We have a zero-tolerance approach to modern slavery and human trafficking and are committed to acting ethically in all our business relationships.

We are committed to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place within our business or supply chains.

2. Scope

This policy applies to all persons working for or on behalf of Heads Up Limited, including employees, contractors, suppliers and business partners.

Although we are a small organisation, we recognise our responsibility to ensure that our business activities do not contribute to modern slavery or human trafficking.

3. Our Business and supply chains

Heads Up Limited is a small business based in the United Kingdom employing a small team of staff. 

We primarily work with reputable suppliers and partners and expect them to share our commitment to ethical business practices.

4. Supplier Expectations

We expect our suppliers and business partners to:

• Comply with all applicable laws relating to modern slavery and human trafficking.
• Operate with integrity and transparency in their business practices.
• Ensure that slavery, forced labour, and human trafficking are not taking place in their own operations or supply chains.

 

Where possible, we will seek to work with suppliers who demonstrate responsible and ethical standards.

5. Due diligence processes

Prior to engaging any new Supplier, contractor, or business partner, the Company shall:

• conduct risk assessments based on geographic location, industry sector, and nature of goods or services provided;
• review the prospective party’s own modern slavery policies and procedures;

 

For existing Suppliers, contractors, and business partners, the Company shall:

• conduct periodic reviews of their modern slavery compliance status;
• monitor public records and media reports for any allegations or evidence of modern slavery practices.

6. Risk assessment and management

The Company shall conduct periodic risk assessments to identify and evaluate the risk of Modern Slavery occurring within its operations and Supply Chains. 

Risk assessments shall be conducted at least annually and additionally when:

• entering into new business relationships or partnerships;
• expanding operations into new geographical regions;
• introducing new products or services;
• following any incident or allegation relating to Modern Slavery; or
• when there are significant changes to the Company’s operations or Supply Chain.

 

The risk assessment process shall include:

• mapping of the Company’s Supply Chain to identify all tiers of suppliers and subcontractors;
• identification of geographical regions, industry sectors, and types of work that present higher risks of Modern Slavery;
• assessment of the vulnerability of Workers in the Company’s operations and Supply Chain;
• evaluation of existing controls and their effectiveness in preventing Modern Slavery;
• identification of gaps in current safeguards and control measures; and
• prioritisation of risks based on likelihood and potential impact.

 

High-risk factors that shall be considered during risk assessments include but are not limited to:

• operations in countries with weak governance, rule of law, or high prevalence of use of migrant or temporary Workers;
• industries known to have higher risks of Modern Slavery including agriculture, construction, manufacturing, and hospitality;
• complex Supply Chains with multiple tiers of subcontracting;
• use of labour agencies or recruitment intermediaries; and
• production of goods or services requiring low-skilled labour.

 

Risk assessment findings shall be documented and reviewed by senior management.

7. Responsibility for the Policy

The Director of Heads Up Limited has overall responsibility for ensuring this policy complies with legal and ethical obligations and that it is implemented effectively.

All employees are responsible for familiarising themselves with this policy and reporting any concerns.

8. Reporting Concerns

Employees or partners who believe that modern slavery or unethical labour practices may be occurring within our business or supply chain should report their concerns to the company director.

All concerns will be taken seriously and investigated where appropriate.

9. Policy Review

This policy will be reviewed periodically to ensure it remains appropriate for the size and nature of the business.

Approved by:
Sonia Gill
Director
2/3/2026

Review date: 01/03/2027