MODERN SLAVERY AND HUMAN TRAFFICKING POLICY
Tupi Solutions Limited · Version 1.0 · Adopted 20 October 2026 · Owner: Director · Modern Slavery Act 2015
1. Our position
Tupi Solutions Limited does not tolerate modern slavery or human trafficking in any part of its business or its supply chain. We are committed to acting ethically and with integrity, and to putting in place controls proportionate to the risk we actually carry.
2. The statutory position, stated plainly
Section 54 of the Modern Slavery Act 2015 requires a commercial organisation with a turnover of £36 million or more to publish an annual slavery and human trafficking statement. Tupi Solutions Limited is substantially below that threshold, so no statement is required of us by law.
This policy is adopted voluntarily. We publish our position because customers in health and care are entitled to ask it of their suppliers, and because saying we are below a threshold is not the same as saying we have considered the question. We have considered it, and this document is the answer.
3. Our business, and where the risk actually sits
Tupi writes and operates software. It has no manufacturing, no physical goods, no overseas production, and no agency, temporary or outsourced labour of any kind. Everyone who works for the company is a director of it, engaged directly and not through any intermediary.
Tupi engages no interpreters and no freelance workforce. Where our software supports an agency’s interpreter base, those interpreters are engaged by that agency and not by us. We never contract, pay or direct a worker in the delivery of interpreting.
| Where our risk is | Assessment |
|---|---|
| Our own workforce | Very low. All personnel are directors, engaged directly, with right to work verified and recorded. No labour provider, no agency, no umbrella company and no subcontracted staff |
| Our software supply chain | Low. Our suppliers are software and cloud service providers in the United Kingdom, the European Union and the United States. Where a supplier publishes its own modern slavery statement we rely on it; several of our suppliers are below the turnover threshold at which a statement is required of them, as we are ourselves, and for those we expect the same proportionate position we take ourselves. |
| Hardware | The one area of residual risk, and it is indirect. Laptops and a mobile telephone are bought from mainstream manufacturers whose own supply chains extend into electronics manufacturing. We buy from the manufacturer or an authorised reseller and rely on their published statements |
| Professional services | Low. Accountancy, legal and certification bodies, all United Kingdom regulated |
We have not identified any part of our operations as carrying a high risk of modern slavery. That conclusion reflects the nature and scale of a software business with no contracted labour, and is not a claim that the risk is zero, and it is reviewed annually and whenever we take on a new category of supplier.
4. What we actually do
| Right to work | Verified and recorded for every person before they work for us. It is a step in our joiners process, not a separate exercise |
| Direct engagement | We do not use employment agencies, labour providers, umbrella companies or recruitment intermediaries. If we ever do, that supplier will be assessed before engagement |
| Supplier assessment | New suppliers handling personal data are assessed and recorded in our supplier register. Modern slavery is part of that assessment where the supplier provides goods or people rather than software |
| Payment practices | We pay suppliers and any contractor to agreed terms. Late or withheld payment is a recognised driver of exploitation further down a supply chain |
| Reporting a concern | Any concern is raised with the Director, who is the senior accountable person. Concerns may be raised without fear of detriment. A concern about the Director is raised with any other director |
| Awareness | Directors are made aware of this policy on adoption and at each annual review. Given the size and structure of the organisation this is a direct briefing rather than a training module, and saying so is more honest than claiming a course |
5. Our suppliers
We expect every supplier to comply with the Modern Slavery Act 2015 and to be able to evidence it on request. Where a supplier publishes its own statement we rely on it; where one is not required of them, we expect the same proportionate position we take ourselves.
The position for each individual supplier is recorded in our supplier register and not in this policy, because it changes as suppliers grow, are acquired or begin publishing. A policy that asserts what each supplier publishes is out of date the moment one of them changes, and this one deliberately does not.
We will not knowingly engage a supplier that does not meet this expectation, and we reserve the right to terminate where a supplier is found to be in breach.
6. Responsibility and review
| Owner | Andrew Lovell, Director, who is the senior accountable person |
| Review | Annually, and on any material change: a new category of supplier, the engagement of any agency or contracted labour, growth that brings us within scope of section 54, or any concern raised |
| Evidence available on request | This policy, our supplier register, our joiners process and right to work records |
If Tupi’s turnover reaches the section 54 threshold, a published annual statement becomes a legal requirement and this policy is replaced by one.
Adopted: 20 October 2026 · Approved by: Andrew Lovell, Director · Next review: 20 October 2027