Commitment
Proceed Data Management Ltd is committed to conducting business with integrity, transparency, and respect for human rights. We maintain a zero-tolerance approach to modern slavery, forced labour, servitude, and human trafficking in all parts of our operations and supply chain.
Although the Company does not meet the mandatory turnover threshold under Section 54 of the Modern Slavery Act 2015, we voluntarily publish this statement in alignment with the principles of the Act and in support of our broader governance, risk management, and ESG commitments.
Organisational structure and operations
Proceed Data Management Ltd operates within the SAP data management and technology services sector and employs over 100 personnel globally.
Our services include:
- SAP data management consulting
- Data migration and archiving services
- Cloud-hosted and managed services
- Technical project delivery
Our supply chain primarily comprises:
- Enterprise software vendors
- Cloud and hosting providers
- IT hardware suppliers
- Professional services contractors
- Recruitment partners
- Corporate service providers
Governance and oversight
Modern slavery risk is overseen at Board level and integrated into the Company’s wider governance
and compliance framework.
Responsibility for implementation rests with:
- The board of directors
- Senior management
- HR and compliance functions
Modern slavery risk forms part of our broader risk management and supplier governance processes. This statement is reviewed annually.
Policies and Control Framework
The prevention of modern slavery is embedded within our policy framework, including: Modern Slavery Policy
- Anti-bribery and corruption policy
- Whistleblowing policy
- Employee vetting and screening procedures
- Information security and supplier management controls
- Employee code of conduct
These policies:
- Establish ethical standards of behaviour
- Provide reporting and escalation mechanisms
- Define disciplinary consequences for breaches
- Support regulatory and contractual compliance
Policies are reviewed periodically and communicated to employees.
Risk assessment
We adopt a risk-based approach consistent with enterprise governance expectations and ISO-aligned management principles.
Risk factors considered include:
- Geographic risk exposure
- Industry sector risk indicators
- Use of subcontracted labour
- Nature of goods supplied (e.g. hardware manufacturing)
- Level of supplier dependency
Given our professional services and technology-focused operations, we assess inherent modern slavery risk as lower than in manufacturing, construction, agriculture, or logistics sectors. However, we recognise that risk may exist indirectly through global supply chains, particularly within hardware manufacturing.
Risk assessments are reviewed periodically as part of supplier onboarding and ongoing vendor management.
Due diligence – Workforce
We maintain structured recruitment and screening procedures designed to prevent forced labour and unlawful employment practices.
Controls include:
- Verification of identity and right to work in the UK
- Structured reference checks
- Employment history verification
- Screening in accordance with BS7858:2019 where applicable
- Secure document retention aligned with UK GDPR
All employees are engaged under formal contracts of employment with clearly defined terms and protections.
Due diligence – Supply chain
Supplier risk management aligns with enterprise procurement expectations and ISO 27001 supplier control principles.
Our controls include:
- Supplier onboarding review and approval
- Preference for reputable UK/EU-based vendors
- Contractual clauses requiring compliance with applicable laws
- Right to terminate for serious ethical or legal breaches
- Monitoring of critical suppliers
- Encouragement of suppliers to maintain their own modern slavery statements
Where suppliers operate in higher-risk jurisdictions or industries, additional scrutiny may be applied proportionate to risk.
Training and awareness
Employees are expected to:
- Understand indicators of modern slavery
- Escalate concerns promptly
- Comply with Company ethical standards
Awareness is supported through policy communication, onboarding procedures, and management oversight.
Reporting and escalation
The Company maintains clear reporting mechanisms through:
- Line management
- Senior management
- Whistleblowing procedures
Reports are handled confidentially and without retaliation. Investigations are conducted where appropriate and corrective action taken as necessary.
Monitoring and effectiveness
We assess the effectiveness of our approach through:
- Completion of employee vetting procedures
- Supplier due diligence controls
- Policy review cycle
- Monitoring for reported incidents
At the date of this statement, the Company has identified no confirmed instances of modern slavery within its workforce or direct operations.
Continuous improvement principles are applied to strengthen governance controls where required.
Approval
This statement was reviewed and approved by the Board of Directors of Proceed Data Management Ltd on October 2025