Modern Slavery Statement

Xtravirt is committed to preventing modern slavery in our operations and supply chains. This Statement details our ongoing actions.

Xtravirt is committed to preventing modern slavery and human trafficking in all aspects of our operations and supply chains.

This statement relates exclusively to Xtravirt and its operations. Any reference to “our people” pertains solely to individuals working directly for Xtravirt.

In compliance with Section 54, Part 6 of the Modern Slavery Act 2015 (the Act), this statement outlines the measures Xtravirt has implemented to prevent slavery and human trafficking within our operations and supply chains. This statement covers Xtravirt’s financial year ending 31 December 2024 and received approval from the Xtravirt Board of Directors on 11 April 2025.

Introduction

The Act mandates that commercial organisations supplying goods or services with an annual turnover exceeding £36 million must produce and publish a yearly statement on slavery and human trafficking. This statement must outline any measures the organisation has implemented during its financial year to prevent slavery or human trafficking within its operations or supply chains.

Understanding modern slavery

Modern slavery represents a serious international crime affecting millions globally. This growing crisis impacts people regardless of age, gender or ethnicity. Vulnerable individuals, both from the UK and overseas, are coerced into illegal work across numerous sectors including agriculture, construction, hospitality, retail and manufacturing.

Our organisational structure and supply networks

Xtravirt operates as a private limited company, registered in England and Wales.

Our workforce primarily comprises professionally qualified individuals either directly employed by Xtravirt or seconded from an associated pool across a select number of countries. Our employment policies guarantee equitable treatment of all our people globally.

We predominantly work with UK and US-based external suppliers operating in lower-risk sectors such as professional services. However, we also engage with suppliers in the events and travel industries, which present potentially elevated risks.

Our approach to preventing slavery and human trafficking

Xtravirt maintains a zero-tolerance stance towards any breach of the UK’s anti-human trafficking and anti-modern slavery legislation. Should we discover violations of these laws within our supply networks, we will work with those companies to support their compliance efforts.

Our core values—Collaboration, Impact, Innovation and Ownership form the foundation of our organisational culture. These principles guide all our activities at Xtravirt and inform how we conduct business. They define the behavioural expectations for our people in their interactions with colleagues, customers, suppliers and stakeholders worldwide.

We are committed to treating everyone with fairness and consistency, fostering a workplace and business environment characterised by openness, transparency and trust. Our policies and procedures addressing modern slavery risks align fully with our culture and values.

Our targeted procedures for mitigating modern slavery risks include:

  • A ‘Modern Slavery Policy’ for our workforce, detailing key issues, appropriate responses and an internal concerns-raising procedure
  • A formal process for addressing complaints raised by external parties
  • Employment policies safeguarding our people against unfair treatment whilst promoting an equitable and inclusive workplace
  • Rigorous recruitment procedures compliant with applicable employment legislation
  • Competitive remuneration and benefits packages subject to annual review
  • A comprehensive wellbeing strategy encompassing initiatives to support our people’s physical health, mental wellbeing and lifestyle preferences
  • A ‘Procurement Policy’ governing supplier relationships and a ‘Supplier Code of Conduct’ establishing the standards we require.

Due diligence, risk assessment and management procedures

Our policies and procedures incorporate due diligence assessments of suppliers with whom we engage, conducted in accordance with our procurement policy. The use of hotel and conference facilities represents an area of heightened risk. To address this, we evaluate the credentials of companies providing these services as part of our decision-making process for events and travel arrangements.

Performance metrics for evaluating effectiveness

We maintain records of all complaints received via our info@xtravirt.com mailbox or through alternative channels, together with documentation of responsive actions taken. As of the date of this statement, Xtravirt has not identified any instances of modern slavery within our operations or supply chains.

Modern slavery awareness and training

Xtravirt delivers regular training to our people on modern slavery and our related policies, designed to enhance education and awareness of the associated risks. For further information regarding any aspect of this statement, please contact info@xtravirt.com.

Xtravirt accepts full responsibility for this Statement and its associated objectives and will review and update it in accordance with the Act’s requirements.

Updated 7 October 2025

Gavin Jolliffe
CEO
Xtravirt