Modern Slavery Policy

1. Purpose and Scope

Zoocha is committed to operating as an ethical, responsible, and transparent business that upholds human rights and actively prevents modern slavery, forced labour, and human trafficking within its operations and supply chains.

This policy defines Zoocha’s purpose, scope, and commitment to continuous improvement in preventing modern slavery across all entities and business functions. It establishes the framework for compliance with the UK Modern Slavery Act 2015 (Section 54(1)) and demonstrates alignment with Zoocha’s integrated Business Management System (BMS), which is certified to multiple ISO standards.

Specifically, this policy supports and aligns with the following ISO management systems:

• ISO 9001 (Quality Management): ensuring consistent quality and accountability in processes related to recruitment, supplier management, and client service.
• ISO 14001 (Environmental Management): recognising the environmental and social impact of responsible sourcing and procurement.
• ISO 20000 (Service Management): embedding ethical and sustainable practices within service delivery, supplier engagement, and third-party partnerships.
• ISO 22301 (Business Continuity Management): ensuring resilience and ethical continuity of operations even during disruption.
• ISO 27001 (Information Security Management): protecting data integrity and privacy in all employment and supplier relationships.
• ISO 27701 (Privacy Information Management): safeguarding the privacy of individuals whose personal data may be collected or processed during employment or supply-chain engagement.

Scope

This policy applies to:

• All Zoocha legal entities and subsidiaries of Zoocha Group, including Zoocha Ltd (UK), Zoocha SL (Spain), and Zoocha BR (Brazil).
• All Zoocha employees, directors, contractors, agency workers, interns, and suppliers.
• All business activities, including recruitment, procurement, project delivery, managed hosting, and service support under ISO 20000.

It extends to Zoocha’s entire supply chain, including third-party partners, subcontractors, and service providers involved in the design, development, maintenance, hosting, and support of digital services.

Purpose

The purpose of this policy is to:

1. Establish a consistent, auditable approach to identifying, mitigating, and managing modern slavery risks.
2. Ensure compliance with applicable legal, ethical, and ISO requirements.
3. Promote transparency in Zoocha’s business relationships and supplier management.
4. Integrate human rights protection and labour standards into our Service Management System (SMS) and overall BMS governance.
5. Provide clear guidance for employees, suppliers, and clients on the company’s zero-tolerance approach to modern slavery.

2. Organisational Structure and Operations

Zoocha Ltd is a digital agency specialising in the design, development, and support of open-source web applications, principally using Drupal. Founded in 2009 and headquartered in Hertford, UK, Zoocha operates as a group comprising Zoocha Ltd (UK), Zoocha SL (Spain), and Zoocha BR (Brazil).

All entities operate under Zoocha’s BMS, ensuring consistent ethical, environmental, and service management standards across the organisation.

Operational Activities

Zoocha provides full lifecycle digital services, including software development, UX/UI design, managed hosting, DevOps, and client support. These are delivered under the ISO 20000 SMS, which embeds ethical practices, quality control, and continual improvement throughout service delivery.

Supply Chain

Zoocha’s supply chain includes technology vendors (e.g. AWS, Google, Atlassian), software providers, and professional service partners.

Procurement is centrally managed in the UK and guided by Zoocha’s Supplier Management Policy, Supplier Code of Conduct, and modern slavery due diligence framework.

Employment Model

Zoocha employs all staff directly under fair, transparent, and legally compliant contracts in the UK, Spain, and Brazil. The company does not outsource core delivery functions or engage in forced, bonded, or involuntary labour.

All recruitment and employment activities follow strict HR Policies and Procedures, ensuring equality, inclusion, and ethical treatment of all team members.

3. Governance and Responsibilities

Zoocha’s approach to preventing modern slavery and human trafficking is governed through its integrated BMS and associated ISO frameworks.

Clear roles and responsibilities are defined to ensure accountability, transparency, and continuous improvement across all business functions.

Governance Framework

• Governance of this policy operates under the BMS Roles & Responsibilities Register.
• Oversight and performance are reviewed through the Management Review Procedure, ensuring integration with certified ISO standards.
• Findings and improvements feed into the Continuous Improvement internal activity

4. Policy Statement

Zoocha maintains a zero-tolerance approach to all forms of modern slavery, forced labour, and human trafficking.
We are committed to ensuring that every aspect of our operations and supply chain is conducted ethically, transparently, and in accordance with international human rights principles.

Our Commitments

1. Zero Tolerance: No form of slavery, servitude, forced labour, or child labour is tolerated within our business or supply chain.
2. Ethical Business Conduct: We uphold fair treatment, respect, and equality for all individuals involved in our operations and partnerships.
3. Responsible Supply Chain: We require all suppliers, contractors, and partners to comply with our Supplier Code of Conduct, Ethical Trading Policy, and Labour Standards Policy.
4. Compliance & Accountability: All business decisions and supplier relationships must align with relevant laws, Zoocha’s BMS, and ISO standards, including ISO 9001, ISO 14001, ISO 20000, ISO 27001, ISO 27701, and ISO 22301.
5. Transparency & Reporting: We are committed to openly reporting our progress in identifying and mitigating modern slavery risks in line with Section 54(1) of the UK Modern Slavery Act 2015.

Culture and Values

Zoocha’s values guide this policy:

• Open & Inclusive: fostering fairness and respect across all interactions.
• Collaborative & Accountable: working transparently and taking responsibility for our impact.
• Creative & Curious: continuously improving our systems and awareness.
• Adaptive & Agile: responding quickly and effectively to emerging risks, changes in legislation, or new ethical challenges in our supply chain.

These principles underpin how we recruit, manage suppliers, deliver services, and engage with clients. All team members share responsibility for upholding this commitment and must act immediately if they identify or suspect any form of exploitation.

5. Risk Assessment

Zoocha recognises that effective risk management is central to preventing modern slavery and ensuring compliance across its operations and supply chain.

We apply a structured, evidence-based approach to identify, evaluate, and mitigate risks associated with labour exploitation, guided by our ISO-certified standards in our BMS.

Risk Identification

Risks are identified through:

• Supplier and subcontractor due diligence during onboarding and renewal.
• Annual reviews of the Risk and Opportunity Register within the BMS.
• Input from internal audits, management reviews, and staff feedback channels.
• Monitoring emerging regional, industry, and supply chain risk factors.

Key Risk Factors

Zoocha operates primarily in the UK, Spain, and Brazil, where legal and labour protections are strong; however, we recognise potential risk areas including:

• Use of third-party or sub-tier suppliers in higher-risk countries or industries.
• Procurement of hardware or equipment from complex international supply chains.
• Lack of direct oversight of temporary or contract labour (where applicable).
• Emerging geopolitical or economic factors impacting supplier practices.

Risk Assessment and Mitigation

Zoocha uses a risk-based methodology aligned with ISO 31000 principles, assigning risk scores based on likelihood and potential impact. Mitigation measures include:

• Enhanced due diligence and supplier questionnaires for medium and high-risk suppliers.
• Annual review of supplier compliance with the Supplier Code of Conduct.
• Escalation of concerns via the Whistleblowing Policy and documented investigation outcomes.
• Continuous improvement actions logged and managed.

Ongoing Review

Risk assessments are reviewed at least annually, or sooner if there are significant changes to operations or legislation.

Findings and control effectiveness are reported during the Management Review and inform updates to this policy, supplier contracts, and audit schedules.

6. Due Diligence and Supplier Management

Zoocha is committed to maintaining ethical and transparent relationships with all suppliers, partners, and contractors.

We ensure that our supply chain is managed responsibly and that the risks of modern slavery or human rights violations are identified and mitigated through structured due diligence processes embedded in the BMS and the ISO 20000 SMS.

Supplier Standards

All suppliers must:

• Comply with applicable laws on labour, human rights, and anti-slavery.
• Adhere to the Zoocha Supplier Code of Conduct, Ethical Trading Policy, and Labour Standards Policy.
• Maintain transparent recruitment, employment, and subcontracting practices.
• Support independent verification and audits as requested by Zoocha.

Supplier Onboarding and Review

Zoocha applies a consistent due diligence process to all suppliers, covering:

1. Initial Screening: Evaluation of financial stability, reputation, and ethical policies.
2. Risk Classification: Assessment against country risk, industry sector, and dependency level.
3. Policy Verification: Confirmation that anti-slavery and human rights policies are in place and actively enforced.
4. Approval and Registration: Only suppliers that meet Zoocha’s standards are added to the central supplier register in Attio CRM.

Suppliers are re-evaluated annually or when material changes occur, such as acquisitions, operational shifts, or new subcontracting arrangements.

Monitoring and Auditing

Ongoing supplier performance is monitored through:

• Periodic reviews against key compliance indicators.
• Supplier self-assessment questionnaires for higher-risk categories.
• Targeted audits for suppliers or regions presenting increased risk.
• Corrective action plans and re-assessment following any non-conformance.

Audit outcomes are documented within the Supplier Management Policy and inform risk scoring within the Zoocha Risk and Opportunity Register.

Procurement and Contractual Controls

Procurement activities are centrally managed from the UK, ensuring ethical consistency across all territories.
All contracts include clauses requiring compliance with the Modern Slavery Act 2015 and this policy, giving Zoocha the right to terminate relationships with suppliers found to be in breach.

7. Training and Awareness

Zoocha recognises that awareness and education are essential to preventing modern slavery and ensuring all employees and suppliers act ethically and responsibly.

Training and communication on modern slavery form part of the company’s continuous improvement commitment under the Zoocha BMS and its supporting ISO frameworks.

Induction and Core Training

• All new starters receive modern-slavery and ethical conduct training during onboarding, delivered through the HR Learning & Development Framework.
• Training covers legal obligations under the UK Modern Slavery Act 2015, recognising warning signs of exploitation, and how to report concerns safely.
• Employees in supplier-facing or procurement roles receive additional instruction on supplier due diligence and ethical procurement requirements.

Annual Refresher and Awareness Activities

• Mandatory refresher sessions are delivered annually as part of the BMS awareness schedule.
• Refresher content includes updates on legislation, supplier case studies, and improvements arising from the Management Review and internal continuous improvement processes.
• Attendance and completion are tracked in Breathe HR, and performance data is reported quarterly to the Management Team.

Communication and Engagement

• Company-wide awareness campaigns (e.g. Slack announcements, LMS courses, team meetings, or Confluence documentation) reinforce key messages about ethical conduct and reporting mechanisms.
• Suppliers are informed of Zoocha’s anti-slavery expectations via onboarding communications and contractual documentation.
• All staff and suppliers are reminded of available confidential reporting routes, including the Whistleblowing Policy and internal escalation channels.

Continuous Improvement

Training effectiveness is reviewed annually through employee feedback, audit results, and incident analysis.
Improvements are logged in internal registers and incorporated into the next training cycle to ensure the evolution of best practice and sustained compliance.

8. Reporting, Escalation and Victim Support

Zoocha encourages all employees, contractors, and suppliers to report any concerns about suspected modern slavery or unethical conduct without fear of retaliation.

Zoocha is committed to ensuring that all reports are treated seriously, investigated promptly, and resolved transparently.

Reporting Channels

Concerns or suspicions of modern slavery may be raised through any of the following channels:

• Line Manager or HR Manager: for internal reporting and informal guidance.
• Whistleblowing Confidential Webform: enabling secure, anonymous reporting.
• Information Security Manager, Managing Director or Office Manager: for supplier-related or operational incidents.
• External Escalation: Employees, suppliers, or third parties may contact the Modern Slavery & Exploitation Helpline (0800 0121 700) or relevant local authority if preferred.

Reports can be made anonymously, and no employee will suffer detrimental treatment for raising a concern in good faith.

Investigation and Corrective Action

• All reports are logged and investigated in accordance with the Zoocha Issue Management Procedure.
• Findings are reviewed by the Management Team and recorded accordingly.
• Where suppliers are implicated, corrective actions are enforced through contractual mechanisms, and relationships may be suspended or terminated pending the outcomes of investigations.
• Confirmed incidents trigger a Root Cause Analysis (RCA) and a formal review of related controls.

Victim Support and Remediation

Zoocha recognises its responsibility to support victims of exploitation identified through its operations or supply chain. Where cases arise, the company will:

• Cooperate fully with law enforcement and relevant support organisations.
• Provide or facilitate access to appropriate victim assistance, legal advice, or counselling.
• Ensure that no affected individual is penalised or disadvantaged for reporting abuse.

Confidentiality and Data Protection

All reports and investigations are handled in line with the Zoocha Data Protection Policy and ISO 27701 (Privacy Information Management System).

Only authorised personnel have access to case information, and personal data is stored securely and retained only for as long as necessary.

9. Performance Measurement and Continuous Improvement

Zoocha continually monitors, measures, and improves its performance in preventing modern slavery through structured governance under the BMS.

Performance indicators and improvement actions are reviewed through the Management Review process and reported to senior leadership.

Key Performance Indicators (KPIs)

To measure effectiveness, Zoocha tracks the following indicators:

• 100% of employees complete annual modern slavery and ethics training.
• 100% of suppliers undergo due diligence at onboarding and contract renewal.
• Zero tolerance for confirmed incidents of forced, bonded, or child labour.
• Audit completion rate for supplier reviews and risk assessments.
• Timely closure of all corrective actions arising from investigations or audits.

Results are reviewed during Management Review Meetings and form part of the ongoing ISO audit evidence base.

Continuous Improvement Process

Zoocha promotes continual improvement by:

• Recording all findings, recommendations, and opportunities.
• Reviewing incident trends and supplier audit results to identify systemic risks.
• Updating training, supplier guidance, or contractual terms based on lessons learned.
• Incorporating feedback from staff, clients, and auditors into future revisions of this policy.

Audit and Review

The effectiveness of this policy is validated through:

• Internal BMS audits which are conducted at least annually.
• External ISO surveillance and recertification audits.
• Management review of key risks, controls, and KPI performance.

All results are documented and retained for ISO compliance across various standards, ensuring transparency and evidence-based improvement.

10. Policy Review and Document Control

This policy is a controlled document within Zoocha’s Business Management System (BMS) and is managed under the Document Management Policy to ensure accuracy, accessibility, and version control.

Review Cycle

• Reviewed annually, or sooner if legislation, operations, or risk context change.
• Oversight by the CEO, Managing Director and Delivery Director.
• Outcomes recorded in the BMS Management Review to maintain compliance with ISO 9001, ISO 14001, ISO 20000, ISO 27001, ISO 22301, and ISO 27701.

Document Control

• The current version is published on the Zoocha website; previous versions are archived in accordance with the Zoocha Data Retention Policy.
• Version history and ownership are tracked in the BMS Document Register.
• The approved version is shared via Confluence and published publicly on Zoocha’s website to meet obligations under Section 54(1) of the Modern Slavery Act 2015.

Approval

Approved by: Will Huggins, Chief Executive Officer
Effective Date: 21 October 2025  Next Review: October 2026