Modern Slavery Statement

Modern Slavery Statement

1: Opening statement from senior management

This statement is made on behalf of Empresaria Group plc and its subsidiaries (each, a Group Company and together, the Group, we, us or our), an international specialist staffing group.


This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Empresaria’s slavery and human trafficking statement for the financial year ended 31 December 2025.


The Group is guided by core values of innovation, collaboration, accountability, responsibility, and excellence, which underpin its culture and approach to business. These principles support the Group’s commitment to operating with integrity and play a key role in its efforts to prevent modern slavery and human trafficking.


The Group is committed to preventing all forms of slavery, servitude, forced labour, debt bondage and human trafficking from occurring within its business and supply chain, and expects the same high standards from its suppliers.


The Group will provide information, upon request, to competent authorities regarding its compliance with applicable modern slavery legislation.


2: Structure of the organisation and supply chains


In 2025, the Group had an annual turnover of £239 million.


Our brands operate in 13 different countries in Europe, the Americas and Asia Pacific. A full list of Group Companies and their locations can be found in our Annual Report, which can be downloaded from our website at: https://www.empresaria.com/financial-information/company-reports.


As a provider of services rather than goods, our supply chains are limited, being largely restricted to suppliers providing office supplies and services such as IT and payroll to our Group Companies.


The Group expects all suppliers to meet high ethical and legal standards, and we will not engage with any party known to be involved in unethical practices.

Suppliers are expected to operate under appropriate contractual and compliance standards, including cooperation with audit, monitoring, and due diligence activities where required.


3: Policies on modern slavery


As part of our commitment to combating modern slavery, all staff across the Group are required to comply with our policies, which are updated from time to time, including our:


  • Modern Slavery Policy;
  • Whistleblowing Policy;
  • Code of Conduct.


We expect our suppliers to adhere to our policies where applicable and have a zero-tolerance approach to non-compliance.



4: Due diligence processes


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


  • identifying and assessing potential risk areas in our Group Companies;
  • identifying and assessing potential risk areas in our supply chains, where appropriate;
  • introducing preventative measures where high risks are identified;
  • mitigating the risk of slavery and human trafficking occurring in our supply chains;
  • protecting whistle blowers.


5: Risk assessment


Our businesses are constantly evolving. We regularly evaluate the nature and extent of our exposure to the risk of modern slavery occurring in our business and supply chains.


The nature of our business means that we introduce and/or supply individuals to work for our clients. We undertake compliance checks on prospective workers to confirm their identity, proof of address, right to work and other appropriate checks. We also require our clients to provide a safe working environment for our workers.


Our consultants maintain contact with workers supplied to our clients throughout the length of their assignments to ensure their safety and allow them to raise any concerns.


Most of our businesses provide recruitment and staffing services in relation to highly qualified and skilled individuals. They are predominantly engaged in sectors at low risk of modern slavery, such as IT, healthcare and professional services. Most of the locations in which we operate are at very low risk of modern slavery, for example the UK, US and Europe. We therefore consider that most of our businesses do not operate in high-risk sectors or locations.


However, where our Group Companies do supply or introduce lower skilled individuals within higher risk sectors (such as manufacturing), or where we operate in higher risk locations (such as the Philippines, Malaysia, Thailand or India), we review our processes regularly and introduce preventative measures if appropriate.


Most of our supply chains are low risk in terms of modern slavery. Where we have identified a higher risk of modern slavery in certain types of suppliers, such as umbrella companies, we have strict compliance procedures in place and use only accredited or reputable suppliers.


Senior management across our Group Companies have received training on how to report potential modern slavery incidents and are responsible for ensuring that this information flows down to all employees within their business units.


To date, no instances of modern slavery have been identified anywhere in the Group or in our supply chains and there have been no reported breaches of the Modern Slavery Act 2015.


6: Measuring effectiveness


The Group has a compliance team trained to assess our businesses and identify risks associated with failure to comply with legal and regulatory requirements, including risks associated with modern slavery both in the UK and internationally.


We have reviewed the effectiveness of the measures taken to date and are committed to continuous improvement in identifying and evaluating risks and developing measures to help prevent modern slavery and human trafficking in our business or supply chains.


7: Training


Our compliance team is trained to assist our businesses in ensuring that modern slavery and human trafficking do not occur in our businesses or supply chains.


In 2025, we reviewed our modern slavery training materials to ensure that our training is up to date.


All staff are expected to read and familiarise themselves with the Modern Slavery Policy and to confirm that they have done so. Employees can access the Modern Slavery Policy and our modern slavery training materials at any time.


This helps to ensure that staff at all levels within each business are sufficiently aware of the likely indicators of modern slavery to help them identify possible instances and ensure that they know when and how to raise any concerns.


8: Further actions and sign-off


In 2025 we carried out the following steps:


  • we ensured that each operating Group Company designated a senior employee to take responsibility for modern slavery matters within each business;
  • we updated our standard terms of business, which include modern slavery provision;
  • we maintained a central policy hub where staff can easily access all our policies, including the Group’s Modern Slavery Policy and modern slavery training materials, allowing us to update them and notify staff of changes easily;
  • we reviewed and updated our modern slavery training materials, which are tailored for our businesses.


We intend to take the following steps in 2026:


  • continue to ensure that each Group Company has a designated senior employee responsible for modern slavery matters;
  • review and where appropriate update training for key employees in our Group Companies;
  • where we engage with third parties under their own contractual terms that do not include appropriate modern slavery provisions, to request these where appropriate;
  • continue to work together to improve awareness of modern slavery and to ensure all staff are informed of their responsibilities;
  • review the additional safeguards and/or compliance checks we have put in place for our businesses operating in higher risk locations or sectors.

 

This statement was approved by the Board of Directors on 12 May 2026 and signed on its behalf by Nigel Marsh, CEO, on 12 May 2026.