Modern slavery and human trafficking statement

1. Introduction

Modern slavery and human trafficking are grave violations of human rights. BlueBow Research & Consultancy Ltd is committed to preventing them in every part of our operations and our supply chain.

This statement is made voluntarily. Our turnover falls below the threshold at which Section 54 of the Modern Slavery Act 2015 requires a statement, and we publish one because public sector buyers are entitled to understand how their suppliers manage this risk, and because the commitment holds whether or not the law compels it.

Everyone who works with or for BlueBow, whether employed, contracted or engaged as an associate, is entitled to be treated with dignity, respect and fairness, to be paid properly and on time, and to work free from coercion.

2. Our structure and supply chain

BlueBow Research & Consultancy Ltd is a UK-registered small enterprise, company number 13106068, providing user research, service design, evaluation and digital transformation services to public sector clients. Our registered office is 34 Frobisher Way, Greenhithe, DA9 9JN.

We operate fully remotely. We hold no working premises, and the registered office address is administrative. Our team is twelve people, some of whom are based outside the United Kingdom.

Delivery runs through a small core team supported by contracted associates, specialists engaged for the discipline a given engagement needs. Associates are contracted directly by BlueBow under written terms. We describe this openly because it shapes where our risk sits, as set out in the next section.

We do not manufacture, import or export goods. Our supply chain is short and consists of:

• Cloud and software providers, principally our Microsoft 365 tenancy, configured for UK data residency
• Professional services including accountancy, insurance and certification bodies
• IT equipment purchased from UK retailers
• Contracted associates and, on some engagements, specialist subcontractors
• Fieldwork and participant recruitment partners, where a project requires research at scale

3. Where our risk sits

Across our operations as a whole, the risk of modern slavery is low. We are a small professional services firm with a short supply chain of UK-registered providers, and the majority of our spend goes to software, insurance and professional services where the risk is minimal.

A second, smaller consideration is that some of our associates work outside the United Kingdom. We contract those individuals directly, on written terms, with payment made to the individual through traceable channels. We do not engage overseas labour through intermediaries.

4. Due diligence and controls

Our controls are proportionate to a firm of our size. Each one below is in place today.

In how we engage people

• Every associate and subcontractor is engaged under a written contract that sets out scope, rate and payment terms before work begins
• Right to work checks are carried out for UK-based engagements
• Payment is made directly to the contracted individual or company through traceable banking channels. We do not pay in cash and we do not pay through intermediaries who then pay the worker
• We do not use unpaid work, unpaid trials or unpaid internships. Our industrial training placements are paid
• We do not withhold identity documents in any circumstance

In our supply chain

• Anti-slavery terms are included in our standard contracts and procurement templates
• New suppliers are checked for UK registration and legitimate trading status before engagement
• Fieldwork and recruitment partners are asked to confirm their own modern slavery position, including how their field staff are engaged and paid, before we place work with them
• Where a partner cannot give that assurance, we do not place the work

5. Policies

The following policies support ethical conduct across BlueBow and are issued to everyone who works with us:

6. Awareness and training

Everyone joining BlueBow, whether as staff or as a contracted associate, receives an induction covering ethical practice, human rights and the indicators of modern slavery. Awareness is refreshed annually.

Because our exposure sits in subcontracting, the people who commission fieldwork and onboard suppliers carry additional responsibility. The Chief Executive Officer holds accountability for supplier onboarding and for this statement.

7. Raising a concern

Anyone who suspects modern slavery or human trafficking connected to our work, whether they are a member of our team, an associate, a supplier, a client or a member of the public, can report it to us.

8. Commitments for the year ahead

For the year to 31 March 2027 we commit to the following. These are set at a level a firm of our size can genuinely complete.

9. Approval

This statement covers the financial year 1 April 2025 to 31 March 2026 and was approved by the board of BlueBow Research & Consultancy Ltd.