Corporate & Social Responsibility

We provide communications, technology and managed support services to public-sector and commercial customers across the UK. Our supply chain includes manufacturers and distributors of communications and technology equipment, software and service providers, logistics partners, facilities providers, specialist contractors and subcontractors, and providers of temporary or specialist labour. We recognise that our responsibilities extend beyond the way we manage our own employees and include the way we engage with all parties working for us or on our behalf.

Our position is straightforward: people working for Affini, or on Affini’s behalf, should be treated lawfully, fairly and with respect. We do not tolerate forced labour, servitude, human trafficking or any form of exploitation within our business or within the areas of our supply chain that we can reasonably influence.

Our internal Anti-Slavery and Human Trafficking Policy, ERL 23, sets out the controls and reporting routes that support this commitment. It sits alongside our wider management system, including procurement, supplier onboarding, HR, payroll, right to work, whistleblowing and disciplinary processes.

The nature of our work means that our modern slavery risk is most likely to arise through indirect supply-chain activity, including subcontracted services, temporary or specialist labour, logistics, facilities support and the wider manufacture, movement or supply of technology equipment and components. We therefore focus our attention on practical checks and proportionate supplier engagement rather than relying on policy wording alone.

We seek to work with suppliers that operate openly and transparently. Where appropriate and proportionate to the level of risk, Affini may request further information, supporting evidence or an assessment of a supplier’s relevant policies, controls and working practices.

In practice, this means checking that employees have the right to work, maintaining appropriate payroll controls, reviewing suppliers where the nature of the service or engagement creates a higher level of risk, and making sure concerns can be raised without fear of unfair treatment. Where concerns are identified, they are escalated through the appropriate management route and addressed in line with our internal procedures.

Modern slavery awareness and capacity building form part of our preventive controls. Employees whose roles involve recruitment, payroll, procurement, supplier onboarding, contract management, project delivery or oversight of contractors receive role-appropriate training covering common indicators of forced labour and exploitation, higher-risk activities and geographies, responsible recruitment, supplier due diligence, escalation requirements and the confidential reporting routes available through management and whistleblowing procedures. Training is provided at induction where relevant, refreshed at least annually, and supplemented by targeted briefings when legislation, business activities or risk profiles change. Completion is recorded and any overdue training is escalated to the responsible manager.

Management reviews our modern slavery controls and performance at least annually, taking account of changes in the size, structure and activities of the business and its supply-chain risk profile. For the financial year ending 31 December 2025, Affini recorded no confirmed incidents of modern slavery or human trafficking within its business or supply chain, no concerns raised through its whistleblowing or management reporting routes, and no supplier relationships terminated for modern slavery-related reasons. We maintained right-to-work and payroll controls for employees and applied risk-based checks to relevant supplier and contractor engagements. Where complete historic data was not captured centrally for training completion and supplier due-diligence coverage, this has been identified as an improvement action rather than estimated.

For the financial year ending 31 December 2026, our targets are to: achieve 100% completion of modern slavery training by employees in identified relevant roles within 30 days of assignment or annual renewal; risk-assess 100% of new suppliers and contractors before approval; complete enhanced due diligence on 100% of suppliers assessed as higher risk before engagement or renewal; review 100% of reported concerns within five working days and record an agreed action plan where further investigation is required; close agreed corrective actions by their target date, with overdue actions escalated to management; and report performance against these indicators to the Board at least annually.

This statement is made in accordance with section 54 of the Modern Slavery Act 2015 and summarises the steps Affini Technology Limited takes to reduce the risk of modern slavery and human trafficking in its business and supply chain for the financial year ending 31^st December 2025.

19/02/2026