Introduction

It continues to be a priority for Littlefish to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This statement sets out the approach taken by Littlefish during the financial year ending 31 December 2025 to prevent modern slavery and human trafficking in our business and supply chain.

Littlefish seeks excellence in every aspect of our business and strives to ensure the highest standards of professionalism, integrity and ethical business practice. We are committed to conducting our business in a lawful manner and this includes engaging with our suppliers to ensure that they share our high standards. We fully support the objective of the Modern Slavery Act of 2015, which requires businesses to set out what steps they have taken during the financial year to ensure that modern slavery is not occurring in their supply chains and in their own organisation.

Organisation’s Structure

Littlefish is an award winning and rapidly growing IT Services Provider. Through a focused growth plan we have become an established and credible alternative to the ‘usual suspect’ large Multi £Billion IT Service Providers and IT Outsourcers in the mid-market and enterprise. Littlefish delivers business without compromise for customers across a range of industries and organisations. We understand and can support the specific challenges faced in particular sectors across the UK. Our design ensures operational efficiency and security is achieved to the level our customer’s industry demands. We have established a number of key partnerships and alliances, with suppliers, providers and service partners – all chosen because they actively contribute to a key aspect of our operations. We foster long-term relationships with these key partners and avoid making demands that might lead to them violating human rights.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We maintain a robust modern slavery policy, clearly stating our zero-tolerance approach to forced labour, human trafficking, and any form of exploitation.

We operate a Whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals. We conduct all business in an honest and ethical manner. Our Anti-Bribery & Corruption Policy details our zero-tolerance approach to bribery and corruption and commitment to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption. This policy applies to all individuals working for or on behalf of Littlefish in any capacity.

Current processes to counter slavery and human trafficking

  • To ensure that the wider Littlefish service offering complies with our Modern Slavery Policy Littlefish places a flow-down obligation on all suppliers whereby the provisions of the Modern Slavery Act are a contractual obligation and requires our suppliers to complete a supplier onboarding form, detailing their modern slavery practices for review by our legal and compliance team.
  • Our Chief People Officer, who is the named accountable person for overseeing the management and mitigation of modern slavery risks within Littlefish liaises with our Finance and Procurement departments to ensure that internal policies and practices are followed and upheld and risks that are identified are treated with the urgency and respect they deserve.
  • We also have in place systems to identify and monitor potential risk areas in our supply chains. We use Risk Ledger, to conduct comprehensive audits of all suppliers every six months, to identify and mitigate any potential risks of modern slavery within the supply chain. Littlefish also undertakes the Modern Slavery Risk Assessment Tool (MSAT) annually.
  • 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. We will also require our business partners to provide training to their staff and suppliers.
  • All workers and contractors are paid the national minimum wage or above and work less than 48 hours per week over a 17-work period defined within the Working Time Directive (WTD). We pay 100% of our workforce above the national living wage.
  • Our procurement policy highlights our relationship with our suppliers, including our alignment with the Government Prompt Payment Code, fair and transparent communication, and, where possible, forecasting of the purchasing goods and services, sustainable pricing, and the negation of unfair penalties for not meeting orders.
  • Currently, we prioritise SMEs and VCSEs to pay all undisputed invoices within 30 days of receipt, pay all remaining invoices within 60 days, and are working towards full alignment with the Government Prompt Payment Code for payment of all invoices within 30 days.

Our recruitment policy and standard recruitment practices include:

  • Right to Work Checks – Verify that all employees have the legal right to work in the country, which helps prevent the exploitation of undocumented workers.
  • Employment Contracts – Ensure all staff have clear, legal employment contracts outlining their rights and responsibilities.
  • Identity Verification – Implement robust identity verification processes to prevent using forged or fraudulent documents.
  • Our HR department leads our staff welfare, which includes Grievance Mechanisms which focus on establishing confidential and accessible grievance mechanisms for staff to report abuses or concerns related to modern slavery within the workplace.

Further steps

In our continued efforts to ensure a zero tolerance approach to modern slavery and human trafficking, we are implementing the following additional procedures:

  • We will regularly communicate, including an annual update on the importance of addressing modern slavery risks to all employees, using multiple platforms, including our newsletter, intranet posts, management meetings, and induction.
  • We will partner with Hope for Justice to gain insights, conduct training, and assist in monitoring supply chains for any signs of forced labour or exploitation.
  • Where applicable, we will engage with trade unions across the critical tier 1 of our supply chain, ensuring that Unions are informed of our practices, development and approaches to the mitigation of modern Slavery, that they have a voice in labour conditions and that any issues are promptly addressed.
  • We will collaborate with other tech companies, for example Tech UK, to enable us to share best practices, particularly in supply chain transparency and labour rights enforcement, addressing common challenges in the sector.
  • We will implement a KPI for 100% of employees and 75% of key supplier representatives to complete modern slavery training.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2025. It was approved by the board on 22 January 2026.

Signed by the Chief Executive Officer on behalf of the board of directors.