Modern Slavery Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Scholary (a trading name of Scholary Ltd, Company No. 08344083) has taken, and continues to take, to ensure that modern slavery, servitude, forced or compulsory labour, and human trafficking are not taking place within any part of our business or across our supply chains.

Modern slavery is a crime and a violation of fundamental human rights. As a purpose-led consultancy founded on doing what is right, building trust, and creating positive, lasting change, we are committed to acting ethically and with integrity in all our working relationships, and to maintaining effective systems and controls to safeguard human dignity.

Scholary is an independent education and technology consultancy registered in England and Wales, with our registered address based in Wiltshire, United Kingdom. We partner with universities, further education colleges, schools and multi-academy trusts, UK public-sector and defence organisations, and SMEs.

Our core services are delivered by UK-based advisors, educators, engineers, and researchers across four primary disciplines:

• Cloud & Infrastructure Engineering: Solutions architecture, cloud platform engineering, DevOps, and Infrastructure as Code (IaC).
• Full-Stack Software Engineering & Support: Bespoke application engineering, system integration, and operational support.
• Data Engineering & AI Readiness: Data pipelines, governance, and practical AI and LLM model integration.
• Strategic Leadership & Advisory: Digital transformation, technical leadership, and organisational capability building.

Because Scholary provides specialist consultancy and engineering services rather than physical manufacturing, agriculture, or raw material extraction, we consider the inherent risk of modern slavery within our direct operations to be low.

Our supply chain consists primarily of:

• Specialist Technical Associates & Subcontractors: Experienced UK-based engineers, architects, and consultants engaged to support client delivery programmes.
• Cloud, Software & Telecommunications Providers: Regulated cloud infrastructure platforms, software-as-a-service (SaaS) tools, and network providers.
• Professional Services: UK-regulated legal, accounting, insurance, and independent security auditing firms (supporting our ISO/IEC 27001 and Cyber Essentials Plus certifications).
• IT Hardware & Office Supplies: Laptops, peripherals, and workplace consumables procured from established UK distributors.

We recognise that higher modern slavery risks can exist in the upstream global manufacture of electronics and IT hardware, facilities services, and contingent labour supply chains, and we focus our due diligence proportionate to these areas.

Our commitment to preventing modern slavery is supported by our internal policies and external commitments:

• Recruitment, Right-to-Work & Security Vetting: We carry out identity, UK right-to-work, and (where required for public-sector and defence engagements) government security clearance checks on every employee and associate prior to engagement. We never charge recruitment fees to candidates or workers.
• Fair Remuneration & Working Conditions: All Scholary employees and associates are skilled professionals paid well above the UK National Living Wage, with clear written contracts and supportive working practices.
• Fair Payment Code Signatory: Scholary is a signatory to the UK Fair Payment Code. We recognise that unfair or delayed payment terms can create financial pressure down a supply chain, and we commit to paying our suppliers and associates fairly, transparently, and on time.
• Public-Sector & Defence Supply Chain Assurance: As a JOSCAR Registered Supplier and a Government Commercial Agency (GCA) Supplier, we undergo regular independent compliance assessments covering business ethics, labour standards, health and safety, and information security.
• Armed Forces Covenant (Silver ERS): We are a signatory to the Armed Forces Covenant and hold the Defence Employer Recognition Scheme (ERS) Silver Award, reflecting our commitment to fair, inclusive employment practices.
• Whistleblowing & Speak-Up Policy: We encourage all employees, associates, suppliers, and clients to report any concern or suspicion of unethical conduct or labour exploitation without fear of detriment or retaliation.

To identify and manage risk across our supply chain, we apply the following due diligence controls:

• Supplier Evaluation: Before onboarding new suppliers or subcontractors, we assess their corporate standing, regulatory compliance, security posture, and ethical policies. For hardware and cloud providers, we prioritise vendors that publish transparent Modern Slavery Act statements and maintain audited supply chain standards.
• Contractual Obligations: Our subcontractor and associate agreements require strict adherence to all applicable UK employment, tax, and anti-slavery laws, and prohibit unauthorised sub-tier subcontracting without our prior written approval.
• Direct Engagement Verification: Where we engage associates via personal service companies or approved UK agencies, we verify company registration details, insurance, and right-to-work compliance directly.

We ensure that our leadership team and anyone involved in recruitment, associate engagement, or procurement understands the risks of modern slavery and human trafficking, how to spot warning signs, and how to escalate concerns immediately.

We review the effectiveness of our anti-slavery controls annually against the following indicators:

• 100% completion of identity and UK right-to-work checks for all new employees and associates prior to commencement.
• 100% approval of new subcontractors and key suppliers through our supplier onboarding and ISO/IEC 27001 supplier security review process.
• No instances of substantiated modern slavery, forced labour, or human trafficking concerns raised across our operations or supply chain during the current reporting period.
• Continued adherence to our Fair Payment Code prompt payment commitments to suppliers and associates.