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Modern slavery act statement​

Introduction

This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, demonstrates our commitment to tackle modern slavery and sets out the approach taken by STRAT7 Ltd. (STRAT7) to understand whether slavery, servitude, forced labour and/or human trafficking (together “Modern Slavery”) exist in our supply chain.

This statement demonstrates the actions we have taken to eliminate Modern Slavery since our last statement in July 2025 and those that we intend to undertake during the financial year ending 30 June 2027. It is applicable to STRAT7 and all associated STRAT7 companies and subsidiaries, worldwide.

Our business

STRAT7 is a global strategic insight and customer analytics group. We help global brands understand, predict and act on customers’ needs at pace and at scale. We blend cultural, category, and consumer understanding to create impactful customer-centric solutions that are always in-tune with changing consumer needs, to help our clients to put their customers at the heart of all decisions.

STRAT7 is headquartered in the UK, with over 300 employees worldwide and offices in 4 continents. Our supply chain consists of global suppliers of AI technologies, data, research services and consultancy, office supplies and computer software and equipment.

Although the research industry may be considered low risk, we do operate globally and, as such, recognise that it is not without risk. Therefore, STRAT7 is mindful of this and seek to address potential modern slavery risk within our sphere of operations, where possible. 80% of our offices are located in top tier countries, according to Walk Free’s Global Slavery Index, in terms of best governmental response to Modern Slavery [1]. Whilst the majority of our offices are located in countries with a low Modern Slavery prevalence score of under 5, we do maintain 2 offices in Bulgaria, which has a prevalence score of 8.50 [2]. However, all staff in our Bulgarian offices are directly employed by STRAT7.

Where necessary, we work with a network of independent contractors and other 3rd agencies, typically where specialist technical or linguistic skills are required to deliver certain contractual obligations. Whilst this constitutes a relatively small percentage of our extended workforce, we are nevertheless committed to ensuring that there is no modern slavery in our such elements of our supply chain or any other part of our operations.

Group policies & procedures

Our Central Operations and People teams are responsible for implementation of policies and procedures that support the business in meeting its human rights responsibilities. This includes the following:

  • Anti-Bribery and Corruption Policy
  • Anti-Facilitation of Tax Evasion Policy
  • Code of Conduct and Ethics
  • Corporate Social Responsibility and Charity Matching Policy
  • Disciplinary and Grievance Procedures
  • Health, Safety and Wellbeing Policy
  • Environmental Policy
  • Equity Diversity & Inclusion Policy
  • Flexible Working Policy
  • Living Wage Policy
  • Life Event Leave Policy
  • Menopause Support Policy
  • Menstrual Health Policy
  • Supplier Code of Conduct
  • Sustainable Procurement Policy
  • Wellness Leave Policy
  • Whistleblowing Policy

Expectations for employees

Our commitment to eradicating modern slavery is emphasised in our employee training and company policies, which promote ethical behaviours. Our employees are required to abide by our codes and ethics which are set out in our Company Handbook. This includes the expectation that employees will familiarise themselves with the Modern Slavery Act Statement, remain alert to potential violations, and report instances swiftly and appropriately. Our Code of Conduct and Ethics Policy reference all the above policies and was first published in June 2024, replacing an outgoing Employee Handbook. In line with all our policies it is reviewed annually as a minimum. It was last reviewed in December.

Modern Slavery Awareness training is a required new starter training module at STRAT7, and our HR Department ensures all new staff complete the training by tracking progress via our online training portal. Since FY 2023/24 this has been one of our core training modules; as such all staff are required to participate in an annual refresher.

Expectations for suppliers

STRAT7 expects the same high standards which we set for ourselves from those parties with whom we engage, such as our suppliers and customers. We maintain a Supplier Approval Process to assess a potential supplier’s suitability and alignment with our standards and values. During the 2024/25 Financial Year STRAT7 stated that we aimed to seek agreement with our top 90% of our suppliers with our revised Supplier Code of Conduct, which replaced our retired Ethical Trading Policy. Whilst this target has not yet been achieved, this is an ongoing effort and during the 2024/25 financial year we successfully introduced an extensive ESG assessment module, as we stated we intended to, into our Supplier Due Diligence vetting process, which we now require ALL prospective suppliers to complete.

STRAT7 expects that the supplier to maintain one or more policies stating their commitment to eliminate Modern Slavery from their supply chains and our Supplier Code of Conduct includes expectations for the prohibition of modern slavery and child labour; fair and ethical working hours, conditions, and environments; and commitments to freedom of association and non-discrimination.

All prospective new suppliers are required to read and agree to this code, as part of our Due Diligence procedures before being approved.

38% of our approved suppliers have now agreed to this code, which includes a commitment to eradicate Modern Slavery. As we continue to onboard new suppliers, and in tandem with ongoing renewal programme, we have no doubts that we will meet our target in the near to mid-term.

Board oversight

STRAT7’s Board is committed to delivering high standards of corporate governance and managing our Company in a socially responsible and ethical way. We aim to comply with all local laws and regulations applicable to our business and we are equally committed to preventing Modern Slavery in its activities and supply chain.

Speaking up

Employees, suppliers, and any other stakeholders are expected to immediately report any suspected incident of modern slavery in STRAT7’s direct operations or supply chain. Concerns can be confidentially reported to our Group Operations Director, members of our People and Culture Team, their line managers, or through an independent third-party organisation.

Areas for improvement

Whilst we have a supplier management system in place, we know that progression is always possible in how we assess and monitor existing and new suppliers alike, to ensure compliance with our expectations, values and practices. Equally, we recognise that we can make improvements in our upward assessments of the clients we choose to work with.

STRAT7 is very much committed to improving our ethical trading standards and in FY 2023/24 participated in EcoVadis for the first time in our history, achieving the “Committed” status. Once again, we are pleased to be able to report that our score improved with our latest submission in May 2026 and we estimate that our currently score is now approximately just 2 points below the threshold for the Ecovadis Bronze medal. Attaining Silver Medal status continues to be a stated aim and we are more confident than ever that it is within reach [3].

In the meantime, we will continue to review the suitability and efficacy of relevant policies and procedures, to ensure they remain fit-for-purpose.

Finally, we continue to work towards Net Zero and published our first Carbon Emissions Reduction Plan in February 2026, with aim to submit our targets to SBTi for ratification this year. Whilst the activities undertaken towards achieving Net Zero do not contribute towards eradicating Modern Slavery we will ensure that any actions we do take, such as the purchase of carbon credits, are free of Modern Slavery. 

We will provide an update on these actions in the revision of our Modern Slavery Act Statement in July 2027, alongside our progress towards SBTi approved Carbon Emissions Targets. 

This statement is approved by the Board and signed on its behalf by:

Barrie Brien
CEO

July 2026

¹ Based on Walk Free’s Global Slavery Index, 2023
² No change since the 2023/24 statement was issued, no new data available
³ Ecovadis do not publish a fixed score threshold for medal status, medals are based on percentiles when the scorecard is published, together with other eligibility rules. Platinum is the top 1%, Gold the top 5%, Silver the top 15% and Bronze the top 35%.

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