1. Introduction
This statement is made by Atago Green Ltd pursuant to Section 54(1) of the Modern Slavery Act 2015. It sets out the steps we have taken during the financial year ending 31 March 2026 to ensure that modern slavery and human trafficking are not taking place in our business or supply chains.
Atago Green Ltd is a UK-registered private limited company operating as an AI-first insight and analytics business. We provide structured intelligence derived from public-domain regulatory and ombudsman data to regulated firms in the UK financial services sector.
2. Our Business and Structure
Atago Green Ltd is a micro-business with a single director and no employees other than the director. We operate primarily through digital, cloud-based infrastructure and do not operate any physical production or manufacturing facilities.
Our activities are limited to:
- ingestion, structuring, and analysis of publicly available regulatory and ombudsman data;
- delivery of insight products, reports, and analytics to UK financial services clients; and
- provision of associated professional advisory services.
Atago Green's commitments on employment and labour standards — including National Minimum Wage compliance, working time and weekly rest, freedom of association and collective bargaining, non-charging of recruitment fees, and non-retention of workers' original identity documents — are set out in Section 9.6 of Atago Green's Code of Conduct, and apply to the Director and to all future employees, contractors and consultants engaged by Atago Green.
3. Our Supply Chains
Given our size and operating model, our supply chain is limited in scope. We procure the following categories of goods and services:
- Cloud-based software-as-a-service platforms (productivity, data infrastructure, accounting, and communication tools);
- Professional services, principally accountancy; and
- Minor consumables and hardware.
Our suppliers are predominantly established, regulated, or publicly listed technology and professional services companies operating in the UK or in jurisdictions with comparable legal protections. We consider the inherent risk of modern slavery in our supply chain to be low, given its composition and geographic concentration in low-risk jurisdictions.
4. Risk Assessment
We have assessed the risk of modern slavery in our business and supply chain against the following factors:
- Business type: We are a service-based digital business with no physical manufacturing, logistics, or labour-intensive operations.
- Workforce: We have no employees other than the director, and do not engage casual labour or agency workers.
- Supply chain: Our suppliers are principally technology and professional services companies, most of which are publicly listed or otherwise subject to their own Modern Slavery Act obligations.
- Geography: Our operations and the majority of our supply chain are based in the UK or equivalent low-risk jurisdictions.
On this basis, we assess the risk of modern slavery occurring within our business or immediate supply chain to be low. We nonetheless remain committed to monitoring this as the business grows.
5. Due Diligence
Given our current size and operating model, our due diligence approach is proportionate:
- We procure services only from reputable, established providers and review supplier terms before onboarding.
- We do not knowingly engage with suppliers whose practices could expose workers to exploitation or unsafe conditions.
- As the business scales, we will introduce supplier due diligence questions addressing labour standards and modern slavery risk as part of our standard onboarding process.
Our supplier due diligence and in-life monitoring attend to the forced labour indicators recognised by the Home Office and the International Labour Organization, including:
- the charging of recruitment fees to workers;
- the retention of workers' original identity documents;
- restrictions on freedom of movement or freedom of association;
- excessive working hours without adequate rest; and
- payment below the applicable lawful minimum wage.
Suspected indicators identified in the course of any supplier engagement will be escalated to the Director and, where appropriate, reported to the relevant authorities.
6. Policies in Relation to Slavery and Human Trafficking
We are committed to acting ethically and with integrity in all business relationships. Our approach is supported by the following related internal policies:
- Supplier Management Policy: sets out our expectations of suppliers regarding ethical conduct, labour standards, and legal compliance.
- Code of Conduct: articulates the standards of behaviour expected of anyone representing Atago Green, and (at Section 9.6) sets out Atago Green's commitments on National Minimum Wage compliance, working time and weekly rest, freedom of association and collective bargaining, non-charging of recruitment fees, and non-retention of workers' original identity documents.
- Statement of Fact / DDQ Attestation Template: a short, factual attestation (refreshed per questionnaire) confirming Atago Green's position on employment tribunal claims, right-to-work compliance, modern slavery incidents, and related matters commonly raised in procurement due diligence.
We will continue to develop our policy framework as the business grows.
7. Training and Awareness
As a micro-business, formal training is currently addressed through the continuing professional development of the director. We commit to ensuring that any future employees, contractors, or representatives are made aware of the risks of modern slavery and human trafficking, and of our expectations in this regard.
Induction for future hires and for any future material supplier engagement will include the forced labour indicators set out in Section 5 and the labour standards commitments in Code of Conduct Section 9.6.
8. Measuring Effectiveness
We will track the following indicators as our business develops:
- Completion of supplier due diligence questionnaires addressing labour standards for all new material suppliers.
- Inclusion of modern slavery clauses in supplier contracts where applicable.
- Annual review and update of this statement by the director.
No incidents of modern slavery or human trafficking have been identified within our business or supply chain during the period covered by this statement.
9. Approval and Sign-Off
This statement has been approved by the director of Atago Green Ltd and will be reviewed annually or following any material change to our business or supply chain.
- Signed by
- Abby Thomas, Director, Atago Green Ltd
- Date
- 22 April 2026
- Next Review
- April 2027
10. Related Documents
- Code of Conduct (including Section 9.6 Employment and Labour Standards)
- Supplier Management Policy
- Statement of Fact / DDQ Attestation Template
- Data Protection Policy