Modern Slavery &
Anti-Trafficking Policy

1. About This Statement

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the steps that Bille Advisory and Consultancy Services Ltd ("BACS") has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within our business or our supply chains.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking — all of which share the common characteristic of depriving a person of their liberty and are motivated by personal or commercial gain.

2. Our Business

Bille Advisory and Consultancy Services Ltd is a UK-registered multidisciplinary advisory and consultancy firm (Company No. 14679426). We operate across five divisions:

• Consulting — Programme management, systems engineering, institutional reform, and capacity building
• Technology — AI solutions, digital transformation, and application development
• Recruitment — Technical and professional staffing services
• Transport — Transport management, compliance, and operational services
• Community Support — Integration services, advocacy, and social support

We are headquartered in the United Kingdom and deliver services both domestically and internationally.

3. Our Supply Chains

Our supply chains include professional services providers, technology vendors, subcontractors, and freelance specialists. We recognise that supply chain risk varies by geography and sector, and we apply proportionate due diligence accordingly.

We seek to work with suppliers who share our values and who operate to equivalent ethical standards.

4. Policies and Procedures

BACS maintains the following internal policies and procedures relevant to combating modern slavery:

• Recruitment policy — We recruit only through legitimate and transparent channels. We verify the right to work for all employees and contractors and do not use unlicensed labour providers.
• Supplier due diligence — We assess suppliers and subcontractors before engagement and include anti-slavery provisions in relevant contracts.
• Whistleblowing policy — We encourage staff and stakeholders to report any concerns about modern slavery or human trafficking in our business or supply chains without fear of retaliation.
• Code of conduct — Our code of conduct sets out the standards we expect from all staff, contractors, and business partners.

5. Due Diligence

We take the following steps to identify and address the risk of modern slavery in our operations and supply chains:

• Conducting risk assessments of our supply chain, with particular attention to higher-risk sectors, geographies, and engagement types
• Including contractual anti-slavery and anti-trafficking obligations in supplier and subcontractor agreements
• Requesting supplier declarations or evidence of compliance where risk is identified
• Monitoring and reviewing supplier relationships on an ongoing basis

6. Training and Awareness

We are committed to ensuring that all staff understand the risks of modern slavery and human trafficking and know how to identify and report concerns. This includes:

• Awareness training for all staff on joining the business
• Specific guidance for staff involved in procurement and supplier management
• Regular communication to maintain awareness of our obligations and our reporting channels

7. Reporting Concerns

Any person — whether a member of staff, contractor, supplier, or member of the public — who has a concern that modern slavery or human trafficking may be occurring in connection with our business is encouraged to report it immediately.

8. Key Performance Indicators

We measure our effectiveness in combating modern slavery through the following indicators:

• Zero incidents of modern slavery identified within our own workforce
• Percentage of key suppliers who have completed anti-slavery declarations
• Number of staff who have received modern slavery awareness training
• Prompt investigation and resolution of any reported concerns

9. This Statement

This statement is reviewed and updated annually. It has been approved by the Director of Bille Advisory and Consultancy Services Ltd and applies to the financial year ending 2026.