Modern Slavery and Human Rights Policy

Company number 04070379 · 20 Little Britain, London EC1A 7DH
Version 1.0 · Adopted 10 November 2026 · Next review November 2027
Owner: Terry Shuttleworth, Managing Director

1. Our commitment

Morse Digital does not tolerate modern slavery, servitude, forced or compulsory labour, human trafficking or child labour, in our own business or in our supply chains. We support the aims of the Modern Slavery Act 2015 and will act ethically and with integrity in all our business relationships.

We are a small software development company, below the £36m turnover threshold in Section 54 of the Act. We have adopted this policy voluntarily because our public sector and commercial clients expect it, and because it is the right thing to do.

2. Scope

This policy applies to everyone who works for or with Morse Digital: directors, employees, contractors and freelancers. We also expect our suppliers to meet the standards it sets out.

3. Our business and supply chains

We design, build, host and support bespoke web applications for clients in the UK and abroad. Our team is a small number of directly employed, salaried UK professionals working from our London office or remotely. We do not use recruitment agencies, labour providers or temporary or seasonal workers.

Our main suppliers fall into these categories:

IT hardware is our highest-risk category. Electronics manufacturing and the mining of the minerals it uses are known to carry modern slavery risks in parts of East and South-East Asia and Africa. We buy little hardware, and only from large manufacturers and retailers that publish their own Modern Slavery Statements.

Outsourced cleaning and facilities services in our serviced office are a known higher-risk sector in the UK, so we rate this category medium.

4. Our standards

We meet these standards, and we expect our suppliers to meet them too:

• We comply with all applicable local and national laws on employment, wages, working hours, and health and safety.
• Workers are free to end their employment on reasonable notice, and their freedom of movement is never restricted.
• Workers are free to join, or not join, a trade union or other workers' association.
• We never use or threaten violence, harassment or intimidation.
• Workers are never charged recruitment fees, directly or indirectly.
• Overtime is always voluntary.
• We never use child labour.
• We do not discriminate on any protected characteristic.
• We never confiscate or hold workers' original identity documents.
• Where modern slavery is found, we will make sure victims can get remedy, compensation and justice, working with the authorities and specialist support organisations.

5. How we manage risk

• Supplier register. We keep a register of all regular suppliers, recording what they provide, where they operate, our risk rating and whether they publish a Modern Slavery Statement. We review it at least once a year.
• Choosing suppliers. When choosing a new regular supplier, or renewing a significant contract, we consider modern slavery risk. Where a supplier is required to publish a Modern Slavery Statement, we check that it does.
• Higher-risk purchases. We buy hardware only from established manufacturers and retailers with published statements and supplier codes of conduct.
• Fair purchasing. We pay suppliers and freelancers promptly and on agreed terms, and we do not impose unrealistic deadlines or prices on them that could push them towards exploiting workers.
• Our own people. Everyone we employ is paid at least the Real Living Wage, has a written contract, and has their right to work in the UK checked. We never hold identity documents or charge recruitment fees.

6. Training

Everyone who works for us completes modern slavery awareness training when they join and again every year. The Managing Director keeps a record of completion.

7. Reporting concerns

Anyone (staff, contractors, suppliers, clients or members of the public) can raise a concern about modern slavery connected to our business. They may do so anonymously and will not be treated unfavourably for doing so in good faith.

• Email: hello@morsedigital.com (marked "Confidential: Modern Slavery")
• Phone: 020 3002 8923, asking for the Managing Director
• Or independently: the Modern Slavery & Exploitation Helpline on 08000 121 700, run by Unseen

Anyone in immediate danger should call 999.

8. How we respond to a report

1. Acknowledge within 2 working days.
2. Assess and investigate within 10 working days. The Managing Director leads this, taking specialist advice where needed.
3. Protect anyone at risk first. Where appropriate we will refer the matter to the police, to the Modern Slavery & Exploitation Helpline, or through the National Referral Mechanism.
4. Remediate. If a supplier is involved, we will work with them on a corrective action plan. If they will not act, we will end the relationship.
5. Record and review. We record every report and its outcome, and use what we learn to update this policy.

9. Measuring progress

We track these key performance indicators and report them in our annual Modern Slavery Statement:

• the percentage of regular suppliers reviewed and risk-rated in the last 12 months (target: 100%)
• the percentage of staff who completed modern slavery training in the last 12 months (target: 100%)
• the percentage of reports acknowledged and investigated within our response times (target: 100%)
• the number of reports received and the number of corrective actions taken

10. Responsibility and review

The Managing Director is responsible for this policy and for making sure it is followed. It is reviewed every year, and sooner if our business or supply chains change significantly. Breaching this policy may lead to disciplinary action, or, for suppliers, the end of our business relationship.

Signed: Terry Shuttleworth, Managing Director, TTT International Ltd
Date: 10 November 2026