Modern Slavery Statement – Financial Year 2026

Word360 Ltd is not required to publish a modern slavery statement under section 54 of the Modern Slavery Act 2015, because our annual turnover is below the £36 million threshold. We publish this statement voluntarily because we believe the people who work with us, our clients and the communities we serve should be able to see how we identify and respond to the risk of modern slavery.

This statement has been prepared with regard to the Home Office statutory guidance, Transparency in Supply Chains. It describes the steps we took during the financial year and our priorities for the year ahead.

This statement applies to Word360 Ltd and covers the financial year 1 October 2026 to 30^th September 2027.

DEFINITIONS

The Word360 considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

COMMITMENT

Word360 acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Word360 understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Word360 does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Word360 in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Word360 strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in United Kingdom.

OUR BUSINESS AND STRUCTURE

Word360 Ltd is a private limited company, established in 1992 and based in Edgbaston, Birmingham. We provide interpreting and translation services to clients throughout the United Kingdom, including NHS trusts and local authorities. Assignments take place at client locations across the UK, and demand is steady throughout the year.

We employ 83 staff directly and work with a panel of approximately 16,000 freelance linguists covering 157 languages. Our guiding principles commit us to being supportive and caring towards our people, clients, suppliers and partners, investors and the communities we serve, and this statement is part of how we put that into practice.

OUR SUPPLY CHAIN

Our supply chain has three main parts:

• Freelance linguists – most of our interpreting and translation is delivered by self-employed linguists engaged directly by us. Interpreters work across the UK; some translators are based overseas.
• Partner language service providers – where we cannot fulfil a request from our own panel, for example for rarer languages or large translation projects, we subcontract to other agencies in the UK and overseas. These agencies use their own linguists, who form a second tier of our supply chain.
• Operational suppliers – goods and services that support our business, such as IT and software, telephony, office facilities and cleaning, and professional services.

RISK ASSESSMENT

Our overall exposure is lower than in sectors such as manufacturing, agriculture or construction. However, we have identified the following specific risks in our business:

• Linguist engagement. Freelance linguists work independently and are usually paid per assignment. Some may be new to the UK or have limited alternative work. This creates a risk of exploitation, for example low effective pay once travel and waiting time are counted, or a third party controlling a linguist’s work or earnings.
• Identity substitution. There is a risk that someone other than the vetted linguist attends an assignment or uses a vetted linguist’s account, which could conceal exploitation.
• Subcontracted and overseas translation. Partner agencies may use lower-tier linguists whom we do not vet directly, including in countries where labour protections are weaker.
• Operational services. Cleaning and facilities services are recognised as higher-risk sectors in the UK.
• Frontline settings. Where our interpreters work in healthcare, policing, legal or immigration settings, they may meet potential victims of modern slavery. This gives us an opportunity to help identify exploitation, and it also means we must guard against any interpreter having a conflict of interest.

We did not identify any instances of modern slavery in our operations or supply chain during the year. We recognise that this does not mean the risk is absent, and we continue to look for it actively.

DUE DILIGENCE & STEPS

During the year we carried out the following due diligence:

• Linguist onboarding – identity and right-to-work checks, references, qualification checks and mandatory DBS checks as standard, and signature of our Code of Conduct.
• Assignment checks – photo ID verification at booking or attendance, and periodic spot checks with clients.
• Supplier approval – before a supplier joins our Preferred Supplier List, we carry out checks including a search for any convictions or adverse media relating to modern slavery.
• Contractual commitments – our contracts require suppliers to comply with our Anti-Slavery Policy and to confirm that they have taken steps to address modern slavery in their business; hold their own suppliers to account; and pay their workers at least the National Minimum Wage or National Living Wage (UK) or the prevailing legal minimum wage (outside the UK).
• Annual review – we review supplier contracts and our risk assessment each year.

At present, much of our supplier due diligence relies on contractual commitments and supplier self-declaration. Strengthening this is one of our priorities for next year.

POLICIES

The following policies set out our approach. They are reviewed annually by Head of HR, Samantha Toon and are available on request:

• Anti-Slavery Policy – our zero-tolerance position on modern slavery, which applies to all staff and linguists and forms part of our contracts with suppliers.
• Recruitment Policy and Procedure – including identity and right-to-work checks for staff and linguists.
• Whistleblowing Policy – allows staff, linguists, clients, suppliers and their workers to raise concerns in confidence, without fear of retaliation.
• Professional Code of Conduct – sets out the behaviour expected of everyone who represents Word360, including declaring any conflict of interest on an assignment.
• Supplier Policy and Preferred Supplier List – sets out the checks a supplier must pass before we work with it.
• Corporate Social Responsibility Policy.
  
  

TRAINING

All office staff complete modern slavery awareness training at induction and annually. The training covers the indicators of modern slavery, the risks specific to our sector and how to report a concern. Linguists receive written guidance at onboarding / an online briefing and on-going CPD training on recognising signs of exploitation during assignments and how to report them to us.

REPORTING CONCERNS AND RESPONDING