Company: Coeus Software Ltd
Company Number: 05830505
Registered Office: Boho One, Bridge Street West, Middlesbrough, England, TS2 1AE
Website: https://policebox.com
Effective: 5th April 2026
Review Date: Annually
1. Policy Statement
Coeus Software Ltd has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically, with integrity and transparency in all business dealings, and to implementing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chains.
This policy applies to all persons working for or on behalf of Coeus Software Ltd, including employees, directors, agency workers, contractors, consultants, suppliers, and business partners.
2. Definition
Modern slavery includes, but is not limited to:
- Human trafficking
- Forced labour
- Bonded or debt labour
- Servitude
- Slavery
- Child labour (where illegal or exploitative)
- Exploitative recruitment practices
3. Our Commitments
Coeus Software Ltd commits to:
- Comply with the UK Modern Slavery Act 2015
- Maintain a zero-tolerance approach to modern slavery
- Conduct business ethically and transparently
- Implement due diligence procedures in supply chains
- Not knowingly engage with organisations involved in modern slavery
- Take action where risks are identified
- Train relevant staff on modern slavery awareness
- Encourage reporting of concerns without fear of retaliation
>
4. Responsibilities
Directors and Senior Management
Directors are responsible for:
- Anti-Slavery and Human Trafficking Policy
- Supplier Code of Conduct
- Ethical Procurement Policy
- Whistleblowing Policy
- Equality, Diversity and Inclusion Policy
- Recruitment and Right-to-Work Procedures
Managers
Managers must:
- Ensure staff understand this policy
- Monitor suppliers within their responsibility
- Escalate concerns immediately
- Ensure procurement follows due diligence requirements
Employees and Contractors
Employees and contractors must:
- Read and comply with this policy
- Report any suspicion of modern slavery
- Avoid engaging suppliers suspected of unethical practices
- Avoid engaging suppliers suspected of unethical practices
- Cooperate where investigations take place
5. Supply Chain Controls
We aim to ensure our supply chains are free from modern slavery by:
- Conducting supplier onboarding checks
- Requesting supplier compliance confirmations
- Including anti-slavery clauses in contract
- Assessing supplier risk levels
- Monitoring higher-risk suppliers
- Reserving the right to terminate relationships for non-compliance
Higher-risk areas may include:
- Overseas manufacturing
- Electronics and hardware supply chain
- Uniforms and textile
- Logistics and warehousing
- Labour-intensive services
6. Recruitment Controls
Coeus Software Ltd ensures:
- Right-to-work checks for all employees
- No recruitment fees charged to workers
- No forced or involuntary labour
- Employees free to leave employment
- Fair pay and working conditions
- Use of reputable recruitment agencies
- No retention of identity documents
7. Reporting Concerns
Any concerns regarding modern slavery should be reported immediately to:
- Line Manager
- Director / Senior Management
- Email: info@coeussoftware.com
Reports may be made confidentially. Coeus Software Ltd will not tolerate retaliation against anyone raising a concern in good faith.
8. Breaches of this Policy
Any employee found to be in breach of this policy may face disciplinary action, up to and including dismissal.
Suppliers found to be in breach may:
- Be required to implement corrective actions
- Be suspended
- Have contracts terminated
- Be reported to appropriate authorities where necessary
9. Training and Awareness
Coeus Software Ltd will provide modern slavery awareness training where appropriate, particularly for:
- Procurement staff
- Supplier managers
- Senior Leadership
- HR & Recruitment personnel
10. Monitoring and Review
This policy will be reviewed annually. It will be updated whenever required.
Where updated, this will be communicated to employees and suppliers.
This policy may be viewed by customers upon request by visiting this page.
10. Approval
This statement has been approved by the Directors of Coeus Software Ltd.