Modern Slavery and Human Trafficking Policy

Updated 05 December 2025
Approved by: Chief Executive Officer

Policy Owner: Designated Compliance Representative

Review Cycle: Annually

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1. Purpose and Commitment

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This Policy reflects Nimble Global Ltd’s ongoing commitment to act ethically and with integrity in all business dealings and relationships, and to implement effective systems and controls to prevent slavery and human trafficking within our operations and supply chains.

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Although Nimble Global Ltd does not meet the turnover threshold for mandatory reporting under the UK Modern Slavery Act 2015, we voluntarily adopt the principles set out in Section 54 to uphold responsible business conduct globally.

 

2. Organizational Structure and Supply Chains

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Nimble Global Ltd is a UK-registered professional services firm providing contingent workforce compliance advisory and related consulting services to global enterprises.
 

Our structure comprises:

• Executive Leadership: Chief Executive Officer and senior functional leads

• Departments: Advisory Services, Compliance, Human Resources, Finance & Administration, and Marketing & Business Development

• Workforce: Full-time employees and contracted professionals engaged on project-specific assignments

 

Our supply chains primarily involve:

• Technology and software service providers

• Professional advisers (e.g., legal and accounting firms)

• Subcontracted consultants and specialized advisory partners

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3. Policies and Expectations

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We maintain a Business Partners’ Code of Conduct requiring all suppliers, contractors, and partners to uphold:

• Freely chosen employment

• Prohibition of child labor

• Compliance with local employment laws

• Non-discrimination and equal opportunity

• Freedom of association and collective bargaining

• Safe and healthy working conditions

• Compliance with working hours and wage laws

 

4. Due Diligence and Risk Management

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We apply a proportionate risk-based approach to due diligence, including:

• Screening new suppliers and clients for modern slavery convictions or adverse media.

• Including anti-slavery and ethical conduct clauses in all client and supplier agreements.

• Maintaining a Supplier Risk Register with categorization (low / medium / high).

• Conducting annual reviews and spot audits where risks are identified.

• Operating an Incident Response Protocol to investigate and remediate allegations.

• Integrating supplier and client risk reviews into the company’s broader compliance framework.

 

5. Training and Awareness

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All employees and managers must complete annual training on modern slavery awareness and ethical business conduct.
 

Business partners are expected to complete equivalent training or confirm adherence to comparable internal programs.

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Training records are maintained by Human Resources to ensure completion and compliance tracking.

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6. Reporting and Escalation

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Nimble Global provides a confidential and anonymous channel for employees, suppliers, and other stakeholders to report any suspicion of slavery or human trafficking.
 

The Designated Compliance Representative investigates reports, and outcomes are documented. Retaliation against whistleblowers is strictly prohibited.

 

7. Measuring Effectiveness

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We assess effectiveness through:

• Annual policy review and reporting to executive management

• Tracking completion rates of training modules

• Monitoring incidents and remedial actions taken

• Periodic audits of supply chain partners

 

8. Governance and Review

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This Policy is reviewed annually and updated as required to reflect legislative or operational changes.

The Chief Executive Officer retains overall accountability for ensuring that this Policy is implemented and communicated effectively throughout the organization.

 

Signed:

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David Ballew

Chief Executive Officer
Nimble Global Ltd

 

DOCUMENT END.