Introduction
Lightflows Limited is committed to preventing modern slavery and human trafficking in all its forms. This statement sets out the steps we take to ensure that slavery and human trafficking do not occur within our business or supply chains. Although our annual turnover falls below the £36 million threshold requiring a statement under Section 54 of the Modern Slavery Act 2015, we publish this statement voluntarily as part of our commitment to ethical business practices and responsible governance.
Our organisation, business and supply chains
Lightflows Limited is a web development company registered in England and Wales (Company No. 06746184), based at the Surrey Technology Centre, Surrey Research Park, Guildford. We employ approximately 11 people and specialise in Drupal website development, design, and ongoing support for public sector, educational, and commercial clients.
Our supply chain is relatively straightforward and consists primarily of: software licensing and SaaS subscriptions (hosting, development tools, project management platforms), hardware suppliers for office equipment, professional services (accountancy, legal), cloud infrastructure providers, and a small number of specialist freelance contractors engaged on specific project work. We do not manufacture physical goods, operate warehouses, or maintain complex international supply chains.
Policies on slavery and human trafficking
Lightflows operates an Information Security Management System (ISMS) certified to ISO 27001:2022. Within this framework, our approach to modern slavery is supported by the following policies and controls:
Our Supplier Management Policy governs how we select, onboard, and monitor third-party suppliers. This policy requires that suppliers demonstrate ethical business practices and comply with applicable legislation, including the Modern Slavery Act 2015.
Our Supplier Register records all active suppliers and is reviewed annually as part of the ISMS management review cycle. This review assesses whether suppliers continue to meet our requirements, including ethical standards.
Our Starters, Movers and Leavers Policy ensures that all employment is voluntary, properly contracted, and that staff are free to leave their employment in accordance with their contract terms. All employees receive a written contract of employment, are paid at least the National Living Wage, and are entitled to statutory employment rights.
Our Code of Conduct sets the expectation that all staff and contractors act with integrity and report any concerns about unethical behaviour.
Due diligence processes
We carry out due diligence in relation to modern slavery through the following measures:
We verify the identity and right to work of all employees and contractors before engagement. All employment is subject to a written contract with clear terms.
When engaging new suppliers, we consider the nature of their business and whether it presents any risk of labour exploitation.
Our Supplier Register is maintained as part of our ISMS and reviewed annually. This review includes consideration of whether suppliers continue to meet our standards.
Risk assessment
Given the nature of our business, the risk of modern slavery within our direct operations is low. Our workforce is UK-based, professionally qualified, and employed on standard contracts with market-rate salaries. We do not employ unskilled or temporary labour, and we do not operate in sectors typically associated with forced labour.
The areas of our supply chain where risk is comparatively higher, though still low in absolute terms, are: cloud infrastructure providers operating data centres (where cleaning, security, and facilities management may involve subcontracted labour), and hardware suppliers with international manufacturing supply chains.
To manage these risks, we use only reputable, established providers and prioritise suppliers who publish their own Modern Slavery Statements and who demonstrate transparency in their supply chains.
Effectiveness and performance indicators
We measure the effectiveness of our approach through the following indicators:
The percentage of active suppliers reviewed annually through the Supplier Register review (target: 100%).
The number of concerns or incidents relating to modern slavery reported by staff or identified through supplier reviews (to date: zero).
Completion rates for staff awareness of ethical standards and reporting obligations.
The outcome of annual ISMS management reviews, which include supplier management as a standing agenda item.
Training and awareness
All employees receive an induction that covers our expectations regarding ethical conduct and the requirement to report any concerns. Our ISMS training programme, which all staff complete, includes awareness of supplier management responsibilities and the importance of identifying and reporting potential indicators of modern slavery or human trafficking.
Staff are encouraged to raise concerns through our internal reporting procedures without fear of retaliation. Any concern raised would be investigated promptly and, where appropriate, reported to the relevant authorities.
Approval
This statement has been approved by the Director of Lightflows Limited and will be reviewed and updated annually.
Director Lightflows Limited Feb 2026