Modern Slavery Statement

Introduction

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Coaley Peak Ltd's modern slavery and human trafficking statement for the financial year ending 31 March 2025.

Coaley Peak Ltd (company number 11783676, trading as Coaley Peak®) is committed to preventing modern slavery and human trafficking in all its forms within our business and supply chain.

Our Business

Coaley Peak Ltd is a UK-registered consultancy headquartered in Cheltenham, England. We provide strategy, policy advisory, digital marketing, data and AI, market research, and stakeholder engagement services to UK enterprises operating in complex geographic markets.

Our Policies

We operate a number of internal policies to ensure we are conducting business in an ethical and transparent manner. These include:

• Anti-slavery and Anti-human Trafficking Policy — sets out our zero-tolerance approach to modern slavery and human trafficking.
• Anti-Corruption and Bribery Policy — compliance with the UK Bribery Act 2010 and international anti-corruption legislation.
• Code of Conduct, Ethics & Standards — defines the standards of behaviour expected of all personnel.
• Whistleblowing procedures — enabling employees to report concerns without fear of retaliation.

Due Diligence

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

• All suppliers are required to confirm compliance with the Modern Slavery Act 2015 before engagement.
• Supplier contracts include specific anti-slavery clauses and the right to audit.
• We conduct proportionate risk assessments of our supply chain on an annual basis.
• We maintain a register of approved suppliers subject to periodic review.

Risk Assessment

Coaley Peak Ltd operates primarily in the professional services sector within the United Kingdom. We assess the risk of modern slavery within our direct operations as low. However, we remain vigilant to risks that may exist within our wider supply chain, particularly in relation to:

• Sub-contracted labour and freelance personnel
• Technology and infrastructure providers
• Facilities management and cleaning services

Training

All employees receive training on modern slavery awareness as part of their induction. Key personnel involved in procurement and supplier management receive additional training on identifying and responding to potential indicators of modern slavery.

Reporting

Any employee who suspects or identifies a potential case of modern slavery or human trafficking should report it immediately to the Managing Director or via our confidential whistleblowing mechanism. Reports can be made to compliance@coaleypeak.co.uk.

Effectiveness

We measure the effectiveness of our steps to ensure that slavery and human trafficking are not taking place in our business or supply chain through:

• Annual review of supplier compliance declarations
• Monitoring of whistleblowing reports
• Internal audit of procurement procedures
• Review during annual management reviews under ISO 9001

Approval

This statement has been approved by the board of directors of Coaley Peak Ltd and is signed by:

Stephen Grindley
Managing Director, Coaley Peak Ltd
January 2025