Modern Slavery Act Statement

Introduction from the Director

This is the first financial year (year ended 31 March, 2026) in which the Modern Slavery Act 2015 is expected to apply to Fulcrum Digital. Our financial statements for the relevant period are currently unaudited, and the ongoing audit process will formally confirm that our turnover threshold brings us within the scope of the Act. We are presently in the process of securing board approval for our Modern Slavery Statement. We can confirm that the Statement will be finalized, formally approved, and updated in line with statutory requirements.

This is Fulcrum Digital’s initial Modern Slavery Act Statement. It reflects financial year ending 31 March 2026.

As this is our initial Statement, we focus on reflecting Level 1 reporting data points, as set out in the UK Home Office’s Transparency in Supply Chains guidance (March 2025). We will be moving to Level 2 data point reporting in years to follow. 

Despite only just entering the statutory regime, Fulcrum Digital is committed to upholding the standards of ethics, integrity, and human rights across our operations. We are firmly committed to preventing modern slavery and human trafficking in all forms within our business and throughout our supply chain.

We recognise that modern slavery can occur in many forms, including forced labour, servitude, child labour, and human trafficking. Fulcrum Digital maintains a zero-tolerance approach to any practice that compromises human dignity or violates fundamental human rights. We expect the same commitment from all suppliers, partners, contractors, and third parties with whom we engage.

As part of our ongoing efforts to address the risk of modern slavery, Fulcrum is taking and will continue to take the following steps:

• Strengthening due-diligence processes to identify, assess, and monitor potential risks of modern slavery within our supply chain.
• Requiring suppliers and partners to comply with explicit prohibitions on forced labour and human trafficking.
• Enhancing internal governance, policies, and training to ensure employees understand their responsibilities in identifying and escalating concerns relating to modern slavery.
• Reviewing our procurement and vendor-onboarding procedures to ensure ethical sourcing practices are embedded at every stage.
• Investigating and taking appropriate action on any suspected breach.
• Fulcrum Digital remains committed to continuous improvement in our practices to safeguard the rights and well-being of all individuals connected to our operations. We will continue to monitor and enhance our processes to ensure we play a proactive role in combating modern slavery and human trafficking.

1. Modern Slavery Act 2015 requirements

The purpose of this Statement is to comply with the requirements of section 54 of the UK’s Modern Slavery Act 2015.

In particular, the Statement is set out to address each of the following information requirements of the legislation relating to our organisation:

• Our organisation’s structure, its business and its supply chains (section 54(a));
• Our policies in relation to slavery and human trafficking (section 54(b));
• Our due diligence processes in relation to slavery and human trafficking in its business and supply chains (section 54(c));
• The parts of our business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps we have taken to assess and manage that risk (section 54(d));
• Our effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate (section 54(e));
• The training about slavery and human trafficking available to our staff (section 54(f)).

2. Section 54(a): Fulcrum Digital’s structure, its business and supply chains

Our Business

Fulcrum Digital is a leading platform and digital solution engineering company, uniquely positioned to deliver on the end-to-end transformation process from technology consulting, enterprise application & platform provision, and full-scale implementation.  

As such, we are a provider of services in the Information Technology sector. We are a part of the Fulcrum Group Holding LLC (Group), and our ultimate parent company is Fulcrum Digital Inc. Our parent company has its head office in New York, in the United States of America. 

The Group has over 900 employees worldwide and operates primarily in UK, Ireland, USA, India, Brazil, Mexico and Argentina.

Supply Chain Understanding

We recognise that it is crucial for us as an organisation to have oversight of our supply chains so that we can understand the risks of modern slavery along the chain and take action to mitigate against those risks.

As we have only just entered the statutory reporting regime, we have completed a mapping exercise of our Tier 1 supply chain insofar as it is applicable to our UK business.

As a general reflection, our supply chain comprises a diverse range of third‑party suppliers operating across multiple sectors. These include technology and professional services providers, such as software, IT consulting, cloud services, payroll and business process support; hospitality, travel and events providers, including hotels, venues, catering and travel services used for business operations and events (though these are ancillary to our primary business functions); facilities management and on‑site services, such as cleaning, maintenance and security support; logistics and courier services; and marketing, design and specialist consultancy services. 

The majority of our suppliers provide services rather than goods, and many operate in sectors characterised by professional or skilled workforces, although we recognise that certain service categories – such as hospitality, facilities and labour‑intensive support services – may present a relatively higher inherent risk of modern slavery and therefore warrant enhanced oversight.

Our supply chains operate across multiple regions, including United States, India, United Kingdom and Ireland.

Goods and services in our supply chains are sourced as follows:

• Hardware: Sourced from global technology manufacturers and distributors, primarily in Asia and North America.
• Software & Cloud Services: Licensed from multinational providers headquartered in the US and Europe.
• Professional Services: Sourced through recruitment agencies and subcontractors, with due diligence checks on labour practices

Fulcrum Digital itself is primarily a service provider and services to our end clients are delivered by our professionals who are engaged with us as employees/sub-contractors across the geographies in which we operate.

Our Products, Sectors and Services

We maintain records of our main products and services, and the volumes produced as well as the sectors we operate in.

As stated above, we are a leading global provider of IT sector services, with a focus on AI-driven business solutions.

Direct and Indirect Suppliers 

Like many global businesses in our sector, we have a sophisticated procurement system and process. Consequently, we have records of all of our direct suppliers. For the purposes of making this statement, we have also mapped this for our UK business insofar as direct suppliers are involved (including our own subcontractor workforce).

Modern slavery risk management governance

We ensure that we have identified named individuals and specific departments within the organisation to be responsible for our modern slavery risk management.

Primary responsibility for managing our modern slavery governance lies with our Legal department and HR department staff.

Information gathering for this Statement

To prepare this statement, information was gathered by the Legal Department and reviewed together with our external advisers.

3. Section 54(b): our policies on slavery and human trafficking

We aim to have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.

We have an existing Employee Code of Conduct which will support this.

We are also aiming to implement a dedicated supplier code of conduct as soon as practically feasible, now that we have entered the statutory reporting regime.

These policies will reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls aiming to ensure slavery and human trafficking is not taking place in our supply chains.

To the extent necessary, we intend to engage with applicable stakeholders in respect of the development and implementation of modern slavery policies.

4. Section 54(c): due diligence process for slavery and human trafficking

Our supplier relationships are governed by a robust procurement process. We are also aiming to implement a dedicated supplier code of conduct as soon as practically feasible, now that we have entered the statutory reporting regime.

5. Section 54(d): identifying, assessing and managing risk of slavery and human trafficking 

As identified above, we have only just entered the statutory reporting regime.

Most of our current supply chain relates to other professional services, though we do also utilise suppliers in sectors that do not have a direct input into our own supply chain (such as in the hospitality and events industry), facilities management (including cleaning) and our own external advisers (legal, accounting, marketing, etc). 

As indicated above, the majority of our suppliers provide services rather than goods, and many operate in sectors characterised by professional or skilled workforces, although we recognise that certain service categories (such as hospitality) may face a higher risk.

Looking ahead, we will be pleased to now undertake a comprehensive modern slavery risk assessment including identifying, assessing and managing the risk of slavery and trafficking within our business and supply chains. We intend to review this annually in preparation for making our annual Modern Slavery Act Statement. We will aim to identify the highest priority modern slavery risks to workers within our business and supply chains.

6. Section 54(e): monitoring and evaluation: our effectiveness in combating slavery and human trafficking

We intend to review and evaluate our effectiveness, so we can adjust our approach, at least once every two years.

At this stage, as we have only just entered the formal statutory regime, our focus will be on setting practical and achievable goals during the next reporting period.

As part of any monitoring and evaluation process, we will ask our HR and our internal legal team to periodically review developments and to have guardianship of our policies and procedures, assisted by external consultants where appropriate.

7. Section 54(f): training

As part of entering the statutory regime, we intend to implement formal awareness training for key staff, such as those in our Legal and HR teams, and those who are directly responsible for overseeing our procurement processes.