MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
For the Financial Year Ending 31 December 2025
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2025. It sets out the steps that Epignosis UK Ltd (hereinafter “Epignosis” or “the Company”) has taken during this financial year to ensure that modern slavery and human trafficking are not taking place in any part of its business or supply chains.
1. Our Business and Organizational Structure
Epignosis is committed to the prevention of modern slavery, servitude, forced labour, and human trafficking in all aspects of its operations and supply chains. We operate in the learning technology sector, providing eLearning solutions including Learning Management Systems (LMS), such as TalentLMS, eFront, and TalentLibrary, to businesses, Non For Profit Organizations and educational institutions. Our business activities are conducted primarily in the United Kingdom and the European Union, with additional operations in other international markets.
Our operations involve working with a diverse range of suppliers, contractors, and partners in the UK, the European Union, and globally.
2. Our Policy on Modern Slavery and Human Trafficking
We maintain a strict Anti-Slavery and Human Trafficking Policy, which reflects our commitment to acting ethically and with integrity in all our business relationships. This policy is embedded within our wider Code of Conduct, which applies to all people working for or on behalf of Epignosis, including employees, contractors, agency workers, interns, and consultants.
Key elements of our policy include:
The Company’s Management Team has overall responsibility for this policy and its implementation. The Chief Operating Officer is primarily responsible for day-to-day implementation, including monitoring effectiveness and ensuring staff awareness and compliance.
3. Due Diligence and Risk Management
Epignosis is committed to identifying and mitigating risks of modern slavery across its operations and supply chains. Our due diligence efforts during the 2025 financial year included:
Supply chain risk assessment: We conducted a periodic assessment of our supply chain to identify sectors and geographies carrying elevated modern slavery risk. Our supply chain is concentrated in the technology and cloud services sector, which we assess as carrying lower inherent risk compared to manufacturing or agricultural supply chains.
Supplier review: We undertook a review of our third-party suppliers and sub-processors against our anti-slavery standards. All material sub-processors are required to operate under written agreements containing anti-slavery and data protection obligations no less protective than our own policies. We are in the process of further strengthening our supplier review framework, and we expect to be in a position to report more detailed findings in our 2026 Statement.
Contractual controls: New and renewed supplier agreements include anti-slavery provisions requiring compliance with applicable modern slavery legislation and cooperation with our audit and investigation processes.
Remediation: Where risks are identified, we work collaboratively with partners to implement appropriate and timely remedial measures. In cases of serious breach or non-cooperation, we reserve the right to suspend or terminate the relationship.
4. Training and Awareness
To maintain a high level of understanding of modern slavery risks across our workforce, we maintain a modern slavery and ethical business conduct training programme for our employees. The programme covers:
Employees in roles with heightened exposure — including compliance, human resources, and supplier-facing functions — receive additional targeted guidance. We expect our suppliers and business partners to provide equivalent training to their own staff, and this expectation is reflected in our contractual terms.
Employees who complete the training are required to confirm their understanding of the Company’s anti-slavery standards and reporting obligations.
5. Effectiveness and Monitoring
During the 2025 financial year, no reports of suspected modern slavery were received — whether from within our operations or from our supply chain. No instances of non-compliance with our anti-slavery standards were identified, and no supplier relationships were suspended or terminated on grounds related to modern slavery.
We recognise that the absence of reported incidents does not in itself confirm the absence of risk, and we continue to invest in awareness, training, and reporting mechanisms to ensure that any issues can be identified and addressed promptly.
We monitor a set of indicators covering training completion, supplier assessment coverage, and reporting activity, and we use the results to refine our approach in line with evolving best practice.
6. Reporting and Whistleblowing
Epignosis supports a culture of openness. All staff are encouraged to raise concerns about modern slavery through internal reporting channels, including their line manager, the Legal Representative or Director/s of the Company or any of Epignosis’ COO, HR Director or any Compliance team member. All reports are treated confidentially, taken seriously, and acted upon promptly in accordance with our whistleblowing policy.
Any breach of our anti-slavery commitment by staff members may be dealt with under our disciplinary procedures and could result in dismissal. For suppliers or business partners, we may terminate or suspend relationships depending on the severity and response to identified issues.
7. Board Approval
This statement has been approved by the Board of Directors of Epignosis on June 30, 2026.
This statement is published on the Company’s website in accordance with the requirements of section 54 of the Modern Slavery Act 2015 and will be reviewed and updated annually.