1. Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Hillmorton Design and Development Ltd has taken to ensure that modern slavery and human trafficking are not taking place in our business or 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. We are committed to acting ethically and with integrity in all our business dealings and relationships to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

2. Our Organisation

Hillmorton Design and Development Ltd is a web design and development agency registered in England and Wales (Company No. 16957863). We are headquartered in London, UK, and provide bespoke web design, digital development, and software solutions exclusively to UK-based businesses, with a core focus on the rail and transport infrastructure sectors.

We are a small, specialist team operating primarily in a digital services capacity. Our workforce is UK-based and our services are delivered remotely and on-site within the United Kingdom.

3. Our Supply Chains

Our supply chain is limited in scope and predominantly digital in nature. Key third-party relationships include:

• Netcup GmbH — Server hosting and infrastructure provider based in Germany, operating within EU regulatory frameworks.
• Cloudflare, Inc. — DNS management and content delivery network services.
• Software and tooling vendors — Providers of development tools, productivity software, and SaaS platforms used in delivering our services.

We do not use labour-intensive manufacturing supply chains. The nature of our business (digital services) significantly reduces our exposure to forced labour and human trafficking risks compared to sectors such as manufacturing or hospitality.

4. Risk Assessment

We have assessed the risk of modern slavery occurring in our business and supply chains. Our assessment considers:

• Geography: We operate exclusively within the United Kingdom and procure services primarily from established EU and UK providers. These jurisdictions have strong labour protections and anti-slavery legislation.
• Sector: The digital services sector carries a low inherent risk of modern slavery compared to labour-intensive industries.
• Supply chain depth: Our supply chain is shallow and primarily involves technology companies subject to their own modern slavery obligations.

We consider the overall risk of modern slavery in our business and supply chains to be low. However, we remain vigilant and committed to continuous improvement in our due diligence processes.

5. Our Policies

We operate the following policies that support our commitment to preventing modern slavery:

• Corporate Ethics Policy — Sets out our commitment to ethical conduct, fair treatment, and legal compliance across all our operations and relationships.
• Equality, Diversity and Inclusion Policy — Ensures all individuals are treated with dignity and respect.
• Whistleblowing Policy — Provides a safe channel for staff and associates to raise concerns about unethical or illegal conduct without fear of retaliation.
• Supplier Due Diligence — When engaging new suppliers or subcontractors, we consider their ethical standards and, where relevant, their own modern slavery compliance.

6. Due Diligence

As part of our ongoing commitment to combating modern slavery, we take the following steps:

• We ensure all staff are employed on fair terms, paid at or above the National Living Wage, and have written employment contracts.
• We do not use zero-hours contracts as a primary employment model and do not engage labour through informal or unverified intermediaries.
• We carry out appropriate checks when engaging subcontractors or freelancers.
• We review our primary technology suppliers' published modern slavery statements where available.

7. Training and Awareness

All members of our team are made aware of the Modern Slavery Act 2015 and the indicators of modern slavery and human trafficking. We include awareness of modern slavery as part of our onboarding process for new team members. Leadership is responsible for maintaining and reviewing this statement annually.

8. Key Performance Indicators

We use the following indicators to measure the effectiveness of our approach:

• Annual review and update of this statement by the Board.
• 100% of staff made aware of this statement and our obligations under the Modern Slavery Act.
• Zero incidents of modern slavery or human trafficking reported in our business or supply chains.
• All new significant supplier relationships reviewed for modern slavery risk before engagement.