Modern Slavery and Human Trafficking Statement


This statement sets out UP3 Services Ltd's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 2024/25.

The organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of UP3 Services Ltd:

UP3 Services Ltd is a ServiceNow software reseller, implementer and managed service provider to businesses in the UK looking to improve the efficiency of their business operations. Our customers are mid-market and enterprise-level businesses operating predominantly across the transport and technology sectors.

Countries of operation and supply

The organisation currently operates in the following countries: United Kingdom

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

The organisation assesses the risk factors of any new client, relationship or service provision during phase one of the project process in line with our due diligence activities.


Responsibility for the organisation's anti-slavery initiatives is as follows:

Policies: The Directors of the Company are responsible for implementing, reviewing and updating an appropriate Modern Slavery Statement

Risk assessments: The Directors of the Company are responsible for highlighting where there may be risks within the supply chain that will need to be assessed.

Investigations/due diligence: The Directors of the Company are responsible for organising the appropriate parties to undertake any required investigations and / or due diligence activities.

Training: Training on the risks, indicators, process and consequences of modern slavery are covered within the induction period for all new employees and then updated as appropriate.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy the organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can [use our confidential helpline/complete our confidential disclosure form].
  • The organisation's employee handbook makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.
  • The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment];
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The organisation continues to review its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015 as appropriate to our risks and relationships.

This statement has been approved by the organisation's board of directors, who will review and update it annually.

Name: Ian Wynn, Head of Managed Service

Date: 21st February 2024