Modern Slavery Statement

1Introduction

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.

2Our Organisation

Hillmorton Design and Development Ltd is a software and web design and development studio registered in England and Wales (Company No. 16957863), with its registered office in London. We provide bespoke websites, web and mobile applications, operations platforms and booking systems to clients across the United Kingdom and, where a project requires it, in Europe. All work is contracted and invoiced in pounds sterling (GBP). Our clients span rail and transport, fleet and logistics, field services, beauty and wellness, community organisations and retail.

We are a small, remote-first team operating entirely in a digital services capacity. Our directors and core team are based in the United Kingdom (in Kent and Berkshire) and work remotely; we do not operate premises, warehouses or manufacturing facilities. Where a project needs additional specialist skills, we hire independent freelancers on a per-gig basis through online freelance marketplaces, currently Upwork and Fiverr. These freelancers may be based in the United Kingdom or in other countries.

3Our 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.
• Freelance marketplaces (Upwork, Fiverr): Platforms through which we find, hire, communicate with and pay independent freelancers for individual gigs, such as design, development or content tasks. The platforms are responsible for verifying the identity of freelancers on their marketplaces and for enforcing their own terms of service.
• Independent freelancers: Individual sellers hired per gig through the platforms above, who may be located in the United Kingdom or overseas. We do not hire freelancers outside these platforms.

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. We recognise, however, that freelance labour sourced through global online marketplaces is the part of our supply chain where risk is highest, which is why we hire freelancers only through established platforms (see sections 4 and 6).

4Risk Assessment

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

• Geography: Our core team is based in the United Kingdom and our infrastructure and technology suppliers are established UK, EU and US providers, in jurisdictions with strong labour protections and anti-slavery legislation. We serve clients in the United Kingdom and Europe. Freelancers engaged through online marketplaces may be located in countries where labour protections are weaker, which we treat as an elevated-risk area.
• 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. It primarily involves technology companies subject to their own modern slavery obligations, and individual freelancers engaged for specific, time-limited pieces of work.
• Freelance marketplaces: Our freelance engagements are individual gigs purchased through Upwork and Fiverr, which operate their own identity verification for sellers and prohibit abusive practices under their own terms. Our relationship with each freelancer is limited to the gig, and all communication, contracting and payment take place on the platform.

We consider the overall risk of modern slavery in our business and supply chains to be low, with freelance engagement identified as the area requiring the most attention. We remain vigilant and committed to continuous improvement in our due diligence processes.

5Our 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.

6Due Diligence

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

• We ensure anyone we employ directly is engaged on fair terms, paid at or above the National Living Wage, and has a written contract.
• We do not use zero-hours contracts as a primary employment model and do not engage labour through informal or unverified intermediaries, such as agents or third parties supplying workers on another person's behalf.
• We hire freelancers only through established freelance marketplaces (Upwork and Fiverr), on a per-gig basis. All communication, contracting and payment take place through the platform, and freelancers are paid the platform price agreed for the gig.
• We rely on these platforms to verify the identity of their freelancers and to enforce their own terms of service and policies, including those prohibiting fraud and abuse.
• If we become aware of any indication of forced labour or exploitation in connection with a gig, we will stop the engagement, report it to the platform and, where appropriate, report our concerns to the Modern Slavery & Exploitation Helpline or the police.
• We review our primary technology suppliers' published modern slavery statements where available.

7Training 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, and anyone in our team who hires freelancers does so only through the platforms described in section 6. Leadership is responsible for maintaining and reviewing this statement annually.

8Key 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.
• All freelance engagements hired, communicated and paid through Upwork or Fiverr.