Modern Slavery Statement
Last updated: May 31, 2026
Document owner: General Counsel
Executive sponsor: Chief Executive Officer
Review cadence: Annual statement with interim updates for material risk changes
Reporting period: Financial year ending 2026-03-31
Legal basis: UK Modern Slavery Act 2015, Section 54
Primary contact: ethicpages+contact@invictosoft.com (subject: Modern Slavery)
Statement from leadership
EthicPages is committed to acting ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to prevent modern slavery and human trafficking in our operations and supply chain.
This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out the steps EthicPages has taken during the reporting period to identify, assess, prevent, and address modern slavery risks.
As a technology company operating a global SaaS platform, our direct labor footprint is limited compared with heavy manufacturing sectors. However, we recognize that risk can still exist in professional services, infrastructure dependencies, equipment sourcing chains, and subcontracted operations. We therefore apply risk-based due diligence and vendor governance controls to reduce exploitation risks.
This statement should be read alongside our Vendor Code of Conduct, ESG Commitments, Privacy Policy, and Security Overview.
Organization structure and business
EthicPages, Inc. is a SaaS provider focused on trust-center and compliance document workflows for B2B organizations. We operate through a distributed workforce and rely on third-party providers for cloud infrastructure, payments, communications, and specialist support services.
| Organizational area | Description |
|---|---|
| Core business | SaaS platform for trust documentation and compliance communication |
| Primary operating model | Digital service delivery with cloud-native infrastructure |
| Direct workforce | Primarily professional, technical, and operational roles |
| Supply profile | Software vendors, cloud and data infrastructure providers, professional services, limited physical procurement |
Although our risk profile differs from goods-intensive industries, we maintain vigilance because labor abuses can occur in service supply chains and indirect vendor relationships.
Policies and governance framework
EthicPages uses policy-based controls to set expectations and create accountability.
| Policy / control | Purpose | Scope |
|---|---|---|
| Vendor Code of Conduct | Defines labor, ethics, anti-bribery, and compliance expectations | All relevant vendors and subcontractors |
| Procurement due diligence workflow | Screens suppliers before onboarding and at renewal | New and renewing vendors |
| Whistleblowing and reporting channels | Enables confidential concern reporting | Employees, contractors, suppliers |
| Contractual compliance clauses | Requires legal and ethical compliance commitments | Material service agreements |
| Corrective action framework | Establishes remediation and escalation process | Vendors with identified gaps |
Responsibility for anti-slavery governance is shared across Legal, Procurement, Security, Finance, and leadership teams.
Supply chain assessment and risk methodology
EthicPages assesses supply chain risk using a proportional methodology based on geography, industry sector, labor intensity, subcontracting complexity, and prior compliance signals.
| Risk factor | Why it matters | Typical indicators |
|---|---|---|
| Geographic exposure | Some jurisdictions carry higher forced labor and trafficking risk | Corruption levels, labor rights enforcement profiles |
| Sector characteristics | Labor-intensive sectors may present higher exploitation risk | Reliance on temporary labor, complex staffing chains |
| Subcontracting depth | Multi-tier structures reduce transparency | Limited visibility into lower-tier providers |
| Control maturity | Weak governance can mask unethical practices | Absent policies, no reporting channels, poor documentation |
| Incident history | Prior allegations or regulatory findings elevate risk | Public enforcement actions, unresolved allegations |
Assessment outputs determine due diligence depth, contractual controls, monitoring cadence, and escalation obligations.
Due diligence procedures
During the reporting period, EthicPages strengthened vendor onboarding and renewal checks to include explicit labor and modern slavery indicators.
| Due diligence step | Activities performed |
|---|---|
| Pre-onboarding screening | Supplier risk questionnaire, sanctions checks, legal entity validation |
| Policy validation | Review of labor rights, anti-slavery, and ethics policies where applicable |
| Contractual safeguards | Inclusion of compliance, audit, and termination clauses for serious violations |
| Risk-tiering | Assignment of low/medium/high risk profile to determine oversight intensity |
| Renewal review | Reassessment at renewal or material service change |
| Escalation process | Legal and Procurement review for unresolved or severe concerns |
For higher-risk suppliers, EthicPages may require additional evidence, executive attestation, and targeted remediation plans before or during engagement.
Training and awareness
Awareness is essential to prevention. EthicPages provides role-specific guidance so teams can identify red flags early and escalate appropriately.
| Audience | Training focus | Frequency |
|---|---|---|
| Procurement and legal | Risk indicators, due diligence, contractual controls, remediation workflows | Annual and onboarding refresh |
| Managers and budget owners | Vendor selection standards and escalation triggers | Annual |
| All employees | Ethical conduct, reporting pathways, and non-retaliation principles | Annual awareness module |
Training materials are reviewed periodically to align with legal developments and observed risk patterns.
Reporting channels and escalation
EthicPages promotes confidential, good-faith reporting of concerns related to labor exploitation, trafficking, coercion, or unethical vendor practices.
| Channel | Intended reporters | Handling approach |
|---|---|---|
| Email: ethicpages+contact@invictosoft.com | Employees, vendors, external stakeholders | Logged, triaged, and routed to Legal + Procurement |
| Manager escalation | Employees and contractors | Escalated to Legal if potential modern slavery indicators exist |
| Procurement incident route | Vendors and supplier contacts | Joint review with risk and legal stakeholders |
EthicPages prohibits retaliation against any individual who raises concerns in good faith.
Effectiveness and KPI framework
We monitor effectiveness using practical key performance indicators designed to measure control coverage and responsiveness.
| KPI | Reporting period result | Direction |
|---|---|---|
| Material vendors screened before onboarding | 100% | Maintain |
| Renewing material vendors reassessed | 96% | Improve to 100% |
| High-risk vendors with documented mitigation plans | 100% of identified high-risk vendors | Maintain |
| Employees in scope completing training | 98% | Improve to 100% |
| Substantiated modern slavery incidents | 0 | Maintain vigilance |
| Median days to close supplier ethics investigations | 21 days | Reduce through process tuning |
KPI interpretation is contextual. A low incident count does not guarantee absence of risk; therefore, proactive controls and open reporting remain essential.
Actions taken in this reporting period
During the covered period, EthicPages implemented the following improvements:
- Updated procurement questionnaires to include explicit modern slavery indicators.
- Added clearer contract language requiring flow-down of labor standards to relevant subcontractors.
- Strengthened risk-tiering criteria for vendor renewal decisions.
- Consolidated issue escalation pathways to improve response consistency.
- Increased visibility of non-retaliation reporting language in internal guidance.
These actions were prioritized to improve early detection, accountability, and remediation quality.
Future priorities
EthicPages plans to advance its anti-slavery program by:
- Expanding traceability expectations for selected high-risk service categories.
- Improving evidence quality standards for vendor policy attestations.
- Increasing cross-functional review cadence for risk exceptions.
- Refining KPI thresholds to better track leading indicators.
- Continuing integration between procurement, legal, security, and ESG governance reporting.
Scenario-led due diligence examples
To improve consistency, EthicPages uses scenario-based review prompts during procurement and renewal. These scenarios are not exhaustive but help teams identify non-obvious warning signals.
| Scenario type | Illustrative trigger | Required action |
|---|---|---|
| Rapid subcontracting expansion | Vendor introduces multiple new subcontractors without transparent controls | Require updated subcontractor list, labor policy evidence, and risk reassessment |
| Unusual pricing pressure | Commercial terms imply unsustainable labor cost structures | Escalate to Procurement + Legal for ethical risk review before approval |
| Insufficient worker grievance channels | Vendor cannot demonstrate confidential reporting process | Require corrective action plan with implementation date |
| Jurisdictional risk escalation | Material service delivery shifts to higher-risk labor environment | Increase monitoring cadence and request enhanced attestation evidence |
Scenario-led review helps reduce false confidence from checklist-only assessments and supports better judgment where risk indicators are mixed.
Remediation and governance assurance
When gaps are identified, EthicPages tracks remediation with clear owners, deadlines, and closure evidence.
| Assurance checkpoint | Minimum requirement |
|---|---|
| Issue ownership | Named accountable lead on vendor and EthicPages side |
| Corrective action detail | Concrete actions, timeline, and measurable outcomes |
| Evidence standard | Documentation sufficient for independent review |
| Escalation threshold | Automatic escalation for missed deadlines or repeated control failures |
| Closure criteria | Confirmed completion and risk re-evaluation before issue closure |
If remediation is not credible or timely for material issues, EthicPages may suspend new work and initiate contractual exit planning to protect affected stakeholders.
Risk limitations and transparency
As with all organizations, no control framework can eliminate risk entirely. Complex supplier ecosystems and indirect subcontracting relationships can limit full visibility. EthicPages addresses this through proportional due diligence, targeted escalation, contractual leverage, and continuous improvement.
We are committed to transparent reporting and practical actions over symbolic commitments.
Relationship to other trust commitments
Modern slavery prevention is part of EthicPages broader trust and governance framework:
- Vendor Code of Conduct for vendor obligations.
- ESG Commitments for governance and sustainability priorities.
- Privacy Policy and Data Processing Agreement for data governance.
- Responsible Disclosure Policy for risk reporting standards.
- Accessibility Statement for inclusive product commitments.
Board approval and signature
This statement has been reviewed and approved by the board (or equivalent governing body) of EthicPages, Inc. for the reporting period set out above.
| Approval item | Detail |
|---|---|
| Approval date | 2026-05-31 |
| Approving body | Board of Directors, EthicPages, Inc. |
| Statement owner | General Counsel |
| Executive signatory | Chief Executive Officer |
Signature block
Signed on behalf of EthicPages, Inc.
Name: ______________________________
Title: Chief Executive Officer
Date: ______________________________
Signature: _________________________
Contact
Questions regarding this statement, due diligence expectations, or concern reporting may be sent to ethicpages+contact@invictosoft.com with subject line "Modern Slavery Statement."
EthicPages remains committed to identifying and reducing exploitation risk through practical controls, transparent governance, and responsible collaboration with employees, suppliers, customers, and external stakeholders.