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Atmosfuture Limited – Modern Slavery and Human Trafficking Policy 

Updated: October 2025 

Policy Owner: Chief Executive Officer / Compliance Lead 

1. INTRODUCTION AND PURPOSE

Atmosfuture Limited is firmly committed to preventing modern slavery, forced labour, and human trafficking in all aspects of our operations, relationships, and supply chains. This policy outlines our approach to identifying, mitigating, and remedying the risks of modern slavery, and demonstrates our commitment to ethical business practices, accountability, and transparency. 

2. SCOPE AND APPLICABILITY

This policy applies to all employees, contractors, suppliers, subcontractors, and third parties carrying out work or providing services on behalf of Atmosfuture Limited, whether based in the UK or overseas. 

3. DEFINITIONS

For the purposes of this policy: 

  • Modern slavery includes forced labour, servitude, debt bondage, human trafficking, and exploitation. 

  • Supply chain refers to all third parties that provide goods or services directly or indirectly to Atmosfuture Limited. 

We adopt a zero-tolerance approach to all forms of modern slavery and human trafficking. 

4. LEGAL FRAMEWORK AND COMMITMENT

Atmosfuture complies with the Modern Slavery Act 2015 and all relevant UK and international legislation. We are committed to acting ethically and with integrity in all our business dealings and relationships. We expect the same high standards from all of our suppliers and partners. 

5. RISK ASSESSMENT AND DUE DILIGENCE

We assess and manage modern slavery risks in our operations and supply chains through the following actions: 

  • Conducting periodic risk assessments to identify areas of vulnerability. 

  • Requiring suppliers to complete self-assessment questionnaires and declare compliance with anti-slavery laws. 

  • Including modern slavery and human trafficking clauses in supplier contracts. 

  • Reserving the right to audit and verify compliance with these standards. 

  • Taking appropriate action where potential or actual breaches are identified. 

6. SUPPLIER CODE OF CONDUCT AND CONTRACTUAL CONTROLS

All suppliers, contractors, and business partners are expected to adhere to our Supplier Code of Conduct, which includes commitments to preventing modern slavery. Contracts with suppliers include terms requiring compliance with all applicable anti-slavery laws and granting Atmosfuture the right to terminate relationships for non-compliance. 

7. TRAINING AND AWARENESS

We provide training to employees, particularly those involved in procurement, supply chain management, and HR, to help them identify and address risks of modern slavery. Training is delivered upon induction and periodically thereafter. Employees are made aware of how to report concerns and are reminded of the company’s zero-tolerance approach. 

8. REPORTING AND WHISTLEBLOWING

Atmosfuture encourages the reporting of any concerns or suspicions of modern slavery within our operations or supply chains. Reports can be made confidentially to management or through designated reporting channels. All reports will be taken seriously, investigated promptly, and handled with sensitivity. Whistleblowers are protected from retaliation in accordance with our Whistleblowing Policy. 

9. INVESTIGATION AND REMEDIATION

Where cases or suspicions of modern slavery are identified, Atmosfuture will take immediate action to investigate and remedy the situation. This may include requiring corrective action plans, engaging external auditors, suspending or terminating contracts, and notifying relevant authorities where appropriate. We will seek to support affected individuals through appropriate channels. 

10. MONITORING, METRICS, AND REVIEW

We monitor the effectiveness of our approach through key indicators, including: 

  • Number of supplier assessments and audits completed. 

  • Percentage of suppliers agreeing to our anti-slavery clauses. 

  • Number of reported or investigated incidents. 

  • Corrective actions implemented. 

 
This policy will be reviewed annually, or sooner if there are material changes in legislation, operations, or risk profile. 

11. GOVERNANCE AND ACCOUNTABILITY

The Chief Executive Officer, supported by the Compliance Lead, is responsible for the implementation of this policy and for reporting progress to the Board. Senior management is responsible for ensuring that this policy is communicated, understood, and followed throughout the organisation. 

12. TRANSPARENCY AND MODERN SLAVERY STATEMENT

Where required by law, Atmosfuture will publish an annual Modern Slavery and Human Trafficking Statement outlining actions taken to prevent modern slavery in our operations and supply chains. This statement will be approved by the Board of Directors and signed by a company director. 

13. RELATED POLICIES AND DOCUMENTS

This policy should be read in conjunction with the following: 

  • Whistleblowing Policy 

  • Procurement Policy 

  • Supplier Code of Conduct 

  • Equality, Diversity, and Inclusion Policy 

  • Employee Handbook and Code of Conduct 

14. REVIEW AND APPROVAL

This policy was last reviewed in October 2025 and will be reviewed annually or when required due to legal or organisational changes. 
 
Approved by: Chief Executive Officer, Atmosfuture Limited 

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