Glow Green Limited ("Glow Green") is committed to preventing modern slavery and human trafficking in all aspects of our business and supply chains. We recognise that modern slavery is a serious crime and a breach of basic human rights. Glow Green is committed to conducting business ethically, lawfully and transparently.
Glow Green operates in the United Kingdom and employs professional and administrative staff, all of whom are based in the UK. Our people are key to our business and success. Therefore, we are committed to providing a working environment that respects human rights and promotes dignity, equality and fairness.
Glow Green has established a robust framework of standards, policies and procedures designed to prevent modern slavery and human trafficking in all our activities. These policies are reviewed regularly and updated as required.
Key documents and practices include:
Code of Conduct: Sets out our expectations for ethical behaviour, responsible business conduct and respect for human rights. Employees must confirm each year that they have read and complied with the Code.
Whistleblowing Policy: Provides clear procedures for raising concerns in a safe and confidential way. It confirms that we do not tolerate retaliation against anyone who speaks up.
Financial Crime Policies: It covers anti-bribery, corruption and anti-money laundering measures designed to prevent criminal activity linked to modern slavery.
All employees receive modern slavery awareness training when they join Glow Green. Refresher training is available as required.
Glow Green works with a range of external suppliers and vendors, including:
Outsourced service providers
Software and hardware vendors
Cloud and hosted IT service providers
Professional services (legal, accounting, consulting, training, audit and banking)
Data providers
Office maintenance, cleaning, security and utilities
Many of these sectors are regulated and require professional skills. Therefore, we assess the overall risk of modern slavery within our core supplier base to be low. However, we recognise that certain suppliers, such as office stationery and cleaning services, may present a relatively higher risk.
Our supplier onboarding and vendor assessments consider modern slavery risks, including risks within suppliers’ own supply chains. Although, we acknowledge that visibility of extended supply chains remains limited. Where possible, we use our position to encourage responsible employment practices and respect for workers’ rights
Glow Green uses a risk-based approach to identify and manage the risk of modern slavery in our business and supply chains. We conduct annual risk assessments to understand where we may be exposed.
uses a risk-based approach to identify and manage the risk of modern slavery in our business and supply chains. We conduct annual risk assessments to understand where we may be exposed.
Risk associated with third-party suppliers
Employment practices and worker protections
Geographic and sector-specific risks
If we identify a risk or concern, we take proportionate and appropriate action. This can include engagement with suppliers and escalation through governance channels.
Glow Green also provides an independent and confidential whistleblowing hotline. Employees, suppliers and other stakeholders can use this to report concerns, including suspected modern slavery or human trafficking.
Glow Green recognises that modern slavery risks can evolve. Therefore, we are committed to improving our approach and increasing our effectiveness:
Regular review and enhancement of policies and procedures
Ongoing employee training and annual policy attestations
Active promotion and monitoring of the whistleblowing hotline
Operational risk reporting to senior management and the Board of Directors
Continuous development of vendor management and due diligence processes
These actions reflect our commitment to implementing effective systems and controls. They also help us maintain transparency and accountability in line with our legal and ethical obligations.
This Modern Slavery Statement will be reviewed each year and updated where needed to reflect changes in our business, supply chains or risk profile. It will remain publicly accessible.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It is Glow Green’s slavery and human trafficking statement for the period 01 April 2025 to 31 March 2026. It was approved by the Glow Green Limited Board of Directors on 20 March 2025.
