Statement under Section 54(1) of the UK Modern Slavery Act 2015 for Black Penny Consulting Ltd.

Introduction
Modern slavery is a criminal act and a violation of fundamental human rights. It encompasses various forms, including slavery, servitude, forced and compulsory labour, and human trafficking. These practices share the commonality of depriving an individual’s liberty to exploit them for personal or commercial gain.

Black Penny Consulting maintains a zero-tolerance policy towards modern slavery and is committed to conducting business with ethical integrity. We pledge to implement and enforce procedures that ensure modern slavery is not present within our own operations or throughout our supply chains.

About Black Penny Consulting
Black Penny Consulting Limited is a limited company registered in England no. 06607756 based at 113 Canalside, Redhill, Surrey, England, RH1 2FH. We are a consulting company providing services to both private and charitable sector organisations.

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted the following due diligence procedures:

  • Standard contractual language regarding a supplier’s compliance with all applicable legislation
  • If necessary, periodic audits on certain suppliers to ensure compliance

Our procedures are designed to

  • Establish and assess areas of potential risk in our business and supply chains
  • Monitor potential risk areas in our business and supply chains
  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains
  • Provide adequate protection for whistle-blowers

Risk and compliance
We do not consider that we operate in a high-risk sector because of the nature of the services we provide and the location and composition of our suppliers.

We ensure all our suppliers adhere to our modern slavery policy. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find evidence of a failure to comply with our policies which contain or reflect anti-slavery measures, we will immediately seek to end our relationship with the relevant supplier.

Embedding the principles
We continue to embed these principles through:

  • Providing annual awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking. This training is reviewed and updated annually.
  • Continuing to take action to embed a zero-tolerance policy towards modern slavery.
  • Ensuring all employees involved in buying, procurement, and recruitment receive training on modern slavery.

In the current financial year, 100% of colleagues have been trained on modern slavery.

This statement was approved by the board of directors of Black Penny Consulting Ltd and signed on 13 November 2024. We will review this statement annually.