Introduction

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This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act

2015 and relates to actions and activities for the financial year ending 31 December 2025.

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Phare HR Consulting, LTD ('the Company', 'we', 'us' or 'our') is committed to preventing slavery and human trafficking violations

in its own operations, its supply chain, and its products. We have zero tolerance towards slavery and require our supply

chain to comply with our values.

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Organisational structure

Phare Hr Consulting, LTD and has business operations in the United Kingdom.

We operate in the HR and employment sector, offering fractional HR support, compliance consulting, payroll management, and talent acquisition services. The nature of our supply chains includes partnerships with HR professionals, consultants, and service providers who support businesses in the UK, US, EU, and Canada.

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For more information about the Company, please visit our website: www.PhareHR.com.

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Policies

We have established internal policies to ensure that our business practices remain ethical, transparent, and free from modern slavery risks. These policies include:

• Recruitment and Selection Policy – We conduct rigorous pre-employment checks to ensure all employees and consultants are legally eligible to work and that no forced or exploitative labour practices occur. For certain roles, additional background checks are required, particularly where individuals may be working with vulnerable populations.

• Supplier Code of Conduct – Our suppliers are required to comply with all local and international employment laws, uphold ethical labour practices, and ensure that modern slavery and human trafficking do not occur in their operations or supply chains.

• Whistleblowing Policy – We encourage all employees, consultants, and suppliers to report any suspected unethical practices within our business or supply chain. Reports are investigated confidentially, and appropriate action is taken where necessary.

 

We ensure that all suppliers are aware of these policies and are expected to adhere to the same standards.

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Due Diligence

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To monitor and reduce the risk of slavery and human trafficking within our supply chains, we have implemented the following due diligence procedures:

• Internal Supplier Audits – We regularly assess our suppliers to ensure compliance with anti-slavery and ethical labour standards.

• External Supplier Audits – Where necessary, we conduct external reviews of key suppliers to verify their adherence to labour laws and ethical sourcing practices.

• Risk Assessments & Monitoring – We evaluate potential risks in our business operations and supply chain and take proactive measures to address any concerns.

 

These procedures are designed to:

• Identify and mitigate risks of slavery and human trafficking in our business and supply chains.

• Monitor and address concerns proactively through continuous engagement with suppliers.

• Ensure compliance with legal and ethical employment standards.

 

Risk and compliance

We evaluate and monitor the risk of modern slavery and human trafficking within our supply chain through:

• Risk Profiling of New Suppliers – Every new supplier undergoes a risk assessment to determine their compliance with labour laws and ethical sourcing standards.

• Annual Supplier Review – We create and maintain an annual risk profile of key suppliers to ensure they continue to meet our ethical and legal requirements.

• Ongoing Supply Chain Monitoring – Our team regularly reviews all aspects of our supply chain based on labour law updates, industry best practices, and supplier conduct.

 

While we do not operate in an industry with high exposure to modern slavery, we recognise that human rights risks exist across all sectors. Our primary suppliers are HR consultants, service providers, and technology platforms based in the UK, US, and EU, which are subject to strict labour laws. However, we remain vigilant and take immediate action against any non-compliance.

If any supplier fails to meet our ethical standards, we will work with them to improve compliance or, if necessary, terminate the relationship immediately.

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Effectiveness & Key Performance Indicators (KPIs)

To measure our effectiveness in ensuring modern slavery does not occur in our business and supply chains, we track the following KPIs:

• Supplier Compliance Checks – We contact 100% of our suppliers every three months to assess their compliance with modern slavery laws and ethical labour standards.

• Annual Supplier Audits – We conduct a full audit of all key suppliers annually to ensure ongoing compliance.

We will continue to develop our monitoring and reporting processes to further strengthen our approach to modern slavery prevention.

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Approval

This statement was approved by the Board of Directors of Phare HR Consulting, LTD on January 1, 2025.