Modern Slavery Policy

Effective Date: 12 November 2025

Zestcode Digital Limited (“we,” “our,” or “us”) has a zero-tolerance approach to modern slavery, forced labour, and human trafficking, whether in our own operations or anywhere in our supply chain.

We fall below the statutory turnover threshold requiring a published Modern Slavery Statement under the Modern Slavery Act 2015, but we publish this policy voluntarily.

1. Scope

This policy applies to everyone working for or on behalf of Zestcode: directors, employees, contractors, freelancers, and consultants. It also applies to suppliers and subcontractors, including overseas contractors we regularly engage.

2. Our Commitment

• We won’t knowingly deal with any business involved in slavery or trafficking.
• We expect suppliers to hold their own suppliers to the same standard.
• Enhanced due diligence applies to overseas contractors and freelancers, covering fair pay, fair conditions, and freely given consent to work.
• We won’t engage suppliers where there’s credible evidence of forced labour, debt bondage, withheld identity documents, or restricted freedom of movement.
• Recruitment practices are fair and transparent, including right-to-work checks where applicable.

3. Due Diligence

• New contractors and suppliers are vetted before engagement.
• Ethical conduct expectations are included in contracts and supplier terms where appropriate.
• Existing relationships are reviewed periodically for changed risk.
• Contractors and freelancers are paid promptly and fairly.

4. Responsibility

Harry Robinson, Director, owns this policy and its implementation. Day-to-day due diligence sits with whoever manages a given contractor or supplier relationship; concerns are escalated to Harry Robinson.

5. Raising Concerns

Report concerns directly to Harry Robinson, Director, in confidence. No one will be penalised for raising a concern in good faith.

6. Training

Anyone engaging contractors, freelancers, or suppliers is made aware of this policy and how to spot signs of exploitation.

7. Review

This policy is reviewed annually, or sooner if legislation, operations, or risk profile change, and is approved by the Director.

If you have any questions or concerns about this policy, please contact us:

Zestcode Digital Limited Email: [email protected] Address: Seven Grange Lane, Pitsford, Northampton, Northamptonshire, NN6 9AP, UK