PHARE HR
CONSULTING, LTD

Modern Slavery Statement — PHARE HR Consulting

Statement date: 30 October 2026
Review: Annually

1. Introduction and commitment

PHARE HR CONSULTING, LTD (the Company) is committed to preventing modern slavery and human trafficking in its business and supply chains. We do not tolerate forced, bonded or compulsory labour, human trafficking, servitude, or the exploitation of adults or children.

This statement is published voluntarily in support of the principles of the Modern Slavery Act 2015. Based on the Company’s current understanding of its turnover, it falls below the £36 million turnover threshold for the Act’s annual statement requirement. We publish this statement because responsible employment practices and vigilance in supply chains matter to our business and the clients we serve.

2. Our business and supply chains

The Company is a London-based HR consulting business operating in the UK, the US, Ghana and Nigeria. We provide HR support and advice to businesses, including support with HR compliance, recruitment processing, payroll management, onboarding, contracts and HR systems.

Our supply chains are relatively limited and principally include:

  • technology, software and cloud-service providers;
  • office and business suppliers;
  • professional advisers and other service providers;
  • freelance contractors and consultants; and
  • recruitment-related service providers, where engaged.

We also work with clients across the UK, the US and Africa. While clients are not part of our supply chain in the conventional sense, our HR advice may help them identify and address exploitation risks in their own workforces.

3. Risk assessment

We consider the risk of modern slavery occurring directly within our small professional-services operation to be low, but not absent. We have no reason to assume that any particular supplier or client is involved in modern slavery. However, risks may arise in complex or international supply chains, including in technology, facilities and recruitment services, and through the use of contractors.

Our HR work also brings a responsibility to remain alert to indicators of forced labour and worker exploitation in client workplaces. Relevant indicators may include restriction of movement, withholding of identity documents or wages, recruitment debt, threats, coercion, unsafe working conditions, or workers being unable to leave employment freely. We recognise that an individual indicator does not, by itself, establish that exploitation is occurring.

4. Due diligence and risk management

We take a proportionate, risk-based approach to due diligence. This includes, as appropriate to the nature and risk of a supplier or engagement:

  • considering the supplier’s identity, services, location and relevant risk factors before engagement;
  • asking relevant suppliers and contractors about their employment and ethical-sourcing practices where appropriate;
  • including or seeking suitable contractual commitments on compliance with applicable employment and anti-slavery laws;
  • reviewing concerns, credible allegations or warning signs raised about suppliers, contractors or client workforces;
  • taking reasonable steps to clarify concerns and, where appropriate, seeking corrective action or ending a relationship; and
  • considering exploitation risks when providing recruitment, payroll and other workforce-related advice to clients.

Where our advice identifies a potential issue in a client’s workforce, we will raise it through the appropriate client contact and recommend that the client investigate and take appropriate action. Our role is to provide HR support; it does not replace a formal investigation by competent authorities or specialist safeguarding professionals.

5. Policies and standards

The Company’s relevant standards and working practices reflect the following principles:

  • modern slavery, human trafficking, forced labour and child exploitation are unacceptable;
  • workers should be engaged voluntarily, paid lawfully and treated with dignity;
  • workers should not be charged unlawful or exploitative recruitment fees or be coerced through threats, debt or retention of documents;
  • suppliers and contractors are expected to comply with applicable labour and human-rights laws; and
  • concerns should be raised promptly and handled sensitively, with appropriate regard for the safety and confidentiality of those affected.

We apply these principles through our employment, supplier and client-engagement processes and review them as the Company’s operations and supply chains develop.

6. Training and awareness

We will maintain awareness among relevant personnel of modern slavery risks, including common indicators of exploitation and the process for escalating concerns. This will be addressed through induction and periodic refresher guidance, with additional role-specific awareness where a person’s responsibilities or client work make it appropriate.

We will encourage personnel to consider these risks when selecting suppliers, engaging contractors, supporting recruitment activity and advising clients on workforce matters.

7. Measuring effectiveness

Given the Company’s size and the nature of its operations, we use proportionate measures to assess the effectiveness of our approach. These may include reviewing:

  • whether relevant suppliers and contractors have been assessed for modern slavery risk where appropriate;
  • whether relevant agreements include suitable compliance commitments;
  • whether personnel with relevant responsibilities receive awareness guidance;
  • whether concerns are raised, recorded and followed up appropriately; and
  • whether any identified issues result in corrective action or a change in supplier or client-engagement practice.

We will use the annual review of this statement to consider whether these measures remain appropriate and whether our processes should be strengthened.

8. Responsibility, approval and review

Responsibility for overseeing this statement and the Company’s approach to modern slavery rests with the Company’s senior management. The statement will be reviewed at least annually and updated sooner if there is a material change in the Company’s business, supply chains or risk profile.

This statement is approved on behalf of PHARE HR CONSULTING, LTD.

Approved by: Amber Aziza
Position: Company Director
Signature: Pending Amber Aziza’s signature
Date of approval: 30 October 2026

9. Reporting concerns

Concerns about modern slavery or human trafficking involving the Company, a supplier, contractor or client workforce may be reported to hello@pharehr.com. Reports will be treated sensitively and reviewed appropriately.

If someone is in immediate danger, contact the relevant emergency services. Do not confront a suspected perpetrator or take action that could put an affected person at further risk.