Modern Slavery Statement
Introduction
This Modern Slavery and Human Trafficking Statement relates to actions and activities during the review period March 2025 – February 2026
The statement sets down Climb Global Solutions UK’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
Purpose
Climb Global Solutions Ltd (“the Company”) operates a zero tolerance to slavery and human trafficking.
This statement is made in relation to the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the current year.
Climb Global Solutions Ltd expects all those in our supply chain to comply with our values and to have suitable anti-slavery and human trafficking policies and processes.
This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Scope
This statement applies to Climb Global Solutions Ltd its employees and managers and extends to any organisation or individual that Climb Global Solutions Ltd conducts business with.
Organisational structure and supply chains
This statement covers the business activities of Climb Global Solutions Ltd which are as follows:
The Company consists of three areas of business. Selling developer and technical software to businesses, distribution of software to resellers and also deliver professional services and support.
The Company operates in the UK but sells worldwide, except to IT embargoes countries.
The Company has reviewed all associated partners and considers our business dealings to be low risk.
Forced labour
We strictly prohibit the use of all forms of forced labour, including prison labour, indentured labour, bonded labour, military labour, modern forms of slavery, and any form of human trafficking. Climb and suppliers must ensure that all work is voluntary and that workers have the freedom to terminate their employment at any time without penalty. This is in accordance with the Modern Slavery Act 2015.
Child labour and minimum age requirements
We do not tolerate child labour in any form. Climb and suppliers must comply with all local and international laws regarding the minimum age for employment. In the UK, children can work part-time from the age of 13, but full time work is only permitted once they have reached the minimum school leaving age. The minimum age for employment should not be less than the age for completing compulsory education and, in any case, not less than 15 years. Suppliers must implement age verification procedures to ensure compliance.
Migrant workers
We are committed to the fair treatment of migrant workers. Climb and suppliers must ensure that migrant workers are employed in accordance with local laws and international standards. Migrant workers should not be subject to any form of discrimination and must have the same rights and protections as local workers. Climb and suppliers must not charge recruitment fees to workers and must provide clear, written contracts in a language the worker understands. This aligns with the Immigration, Asylum and Nationality Act 2006.
Working hours
Climb and suppliers must comply with all applicable laws and regulations regarding working hours, including overtime, rest periods, and holidays. Workers should not be required to work more than the maximum hours of daily labour set by local laws. In the UK, the Working Time Regulations 1998 stipulate that workers should not work more than 48 hours a week on average. Overtime work must be voluntary and compensated at a premium rate.
Equal opportunity and non-discrimination
We are committed to providing equal opportunity in the workplace. Climb and suppliers must ensure that employment decisions are based on merit and not on race, colour, religion, gender, sexual orientation, age, disability, or any other characteristic protected by law. This is in line with the Equality Act 2010.
Community engagement and non-discrimination
Climb and suppliers must engage with impacted communities and take effective measures to remedy any adverse human rights impacts. This includes conducting regular human rights due diligence and implementing corrective actions where necessary.
Responsibility for the company's anti-slavery initiatives is as follows:
1.1 Policies: The Director of Team Engagement & Experience is responsible for creating and reviewing policies. The process by which policies are developed is to look at best practices, taking external advice and creating a policy which is reviewed and agreed by Senior Leaders.
1.2 Risk assessments: The Office Manager and The Director of Team Engagement & Experience are responsible for risk assessments in respect of human rights by a process of reviewing individuals and completing Risk Assessment documentation.
1.3 Due diligence: The Vendor Manager is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.
1.4 The Senior Leadership Team are accountable for making sure the company is acting with due diligence and will ensure any risk assessments are carried out prior to engaging with suppliers and customers.
1.5 The Senior Leadership Team are responsible for supply chain verification for existing and future suppliers in relation to the Modern Slavery Act.
1.6 All Team Leaders, Heads of Department, Senior Managers and the Senior Leadership Team will have training on modern slavery and the implications for the Company.
Training
To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to complete Modern Slavery and Human Trafficking training on their first day of joining the during Induction. Thereafter all Staff will receive mandatory annual Modern Slavery and Human Trafficking training.
Policies
The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.
The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations.
2.1 Protected Disclosure Whistle Blowing Policy (20180104) The Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
2.2 The Company Code of Ethics and Business Conduct The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.
2.3 Corporate Social Responsibility (CSR) Statement Company’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.
Due Diligence Processes for Slavery and Human Trafficking
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes Contract Compliance, building long-standing relationships with suppliers and making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier and invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.
Performance indicators
The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including requiring all [relevant] staff to have completed training on modern slavery as soon as they start with the Company.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated, as necessary. Jane Silk, Matthew Whitton, Caroline Knott, Gerard Brophy and Matthew Hocken endorse this policy statement and are fully committed to its implementation.
Valid for: 19.03.2025 – 18.02.2026
Review and consultation process: Annually from approval date above. The Senior Leadership Team to review and ensure that findings of any risk assessments are taken into consideration and that the policy remains relevant.
Responsibility for Implementation and Training: Team Engagement and Experience.
Distribution: Intranet for internal communications, website and emailed link for affected business partners.
Statement approved by: Matthew Whitton, Chief Operating Officer, 19 March 2025.