Anti-Slavery

Anti-Slavery and Human Trafficking Policy

Silver Bird Consultancy Services Ltd (operating as “Silver Bird Consulting”)

Company Number: 16543539

Registered Address: 82a James Carter Road, Mildenhall, England, IP28 7DE

Email: alexis@silverbirdconsulting.com

Effective Date: 19 October 2026

Policy Statement

Silver Bird Consultancy Services Ltd (“Silver Bird”) has zero tolerance for modern slavery and human trafficking, in its own business and in its supply chains. We act ethically and with integrity in every business relationship, and we expect the same of everyone we work with.

Silver Bird’s turnover is below the £36 million threshold – at which section 54 of the Modern Slavery Act 2015 requires an annual slavery and human trafficking statement. We adopt this policy voluntarily, because our clients, including public bodies, rightly expect their suppliers to meet the Act’s standards.

The directors have approved this policy, and the Managing Director has signed it (see Approval).

1. Scope

This policy applies to everyone who works for or with Silver Bird, in the UK and elsewhere:

Silver Bird’s directors: Alexis Assimacopoulos (Managing Director) and Leah Assimacopoulos (Director);

any associate, freelance trainer, coach or subcontractor Silver Bird engages;

Silver Bird’s suppliers and, through them, its wider supply chain.

2. What Modern Slavery Means

The Modern Slavery Act 2015 covers four forms of exploitation:

Slavery – Treating a person as property, exercising powers of ownership over them

Servitude – Forcing a person to provide services, and often to live on another’s property, under coercion

Forced or compulsory labour – Work or services taken from a person under threat of a penalty, which they have not offered freely

Human trafficking – Arranging or helping a person’s travel so that they can be exploited

Warning signs include people who do not hold their own identity documents, owe debts to an employer or agent, are paid little or nothing, are controlled in where they live or go, or seem frightened or withdrawn.

3. Our Business and Supply Chains

Silver Bird is a UK limited company providing organisation development, culture change and change management consultancy and training. Its only staff are its two directors, and Alexis Assimacopoulos delivers all client work.

Its supply chain is short and mostly made up of UK businesses:

Software, IT services and equipment – Microsoft 365, accounting software, online tools, laptops and phones

Professional services – Accountant, insurance broker, virtual office provider

Travel and accommodation for client work – Rail operators, airlines, hotels

Event services, when we arrange them – Venues, catering, printing

Translation – Professional translators, for example for Welsh-language materials

Associates or subcontractors – None at present; any future use follows the obligations below

4. Risk Assessment

Silver Bird’s direct risk of modern slavery is low: it has no staff beyond its directors and buys mainly professional and digital services from established UK suppliers. The higher risks sit further down the supply chain:

Hotels, catering and venues (Medium Risk) – Hospitality and cleaning are commonly identified as sectors with labour exploitation

IT equipment and printed materials (Medium Risk) – Electronics and print supply chains can involve forced labour overseas

Future associates or subcontractors (Low to medium Risk) – Depends on how they engage their own workers

Professional and software services (Low Risk) – Established UK providers with their own legal obligations

 The directors review this assessment every year, and whenever Silver Bird starts buying something new.

5. Supply Chain Obligations and Due Diligence

Silver Bird will:

Choose reputable suppliers and, in the higher-risk areas above, favour those that publish a modern slavery statement or policy.

Require any associate or subcontractor, in a written agreement, to comply with the Modern Slavery Act 2015 and this policy, to pass the same requirement down their own supply chain, and to report any concern to Silver Bird straight away.

Pay any associate or subcontractor at least the Real Living Wage, within 14 days of a valid invoice.

Not engage anyone through false self-employment, or through umbrella or zero-hours arrangements used to deny workers their rights.

Ask a supplier to explain any warning sign, and act on the answer.

Comply with clients’ own modern slavery and ethical sourcing requirements.

Sign up to the Welsh Government’s Code of Practice: Ethical Employment in Supply Chains within three months of being appointed to supply a Welsh public body, and follow it.

6. How This Policy Is Promoted and Adhered To

Silver Bird puts this policy into practice in five ways:

Published: on Silver Bird’s website, and shared with any client or supplier who ask.

Passed on: given to every associate or subcontractor before they start, and written into their agreement.

Visible to clients: referred to in proposals and tenders, including those to public bodies.

Checked: a short supplier check is recorded the first time Silver Bird buys from a higher-risk area.

Reviewed: compliance is reviewed every two years, alongside this policy.

7. Reporting Concerns

Anyone who suspects modern slavery connected with Silver Bird’s work should raise it straight away:

Someone in immediate danger: call 999.

Tell Silver Bird: Alexis Assimacopoulos, Managing Director, at alexis@silverbirdconsulting.com or 07356 239702. Concerns are handled in confidence.

Or report independently: call the Modern Slavery & Exploitation Helpline on 08000 121 700, or Crimestoppers anonymously on 0800 555 111.

Silver Bird will never penalise anyone for raising a genuine concern, even if it proves unfounded. Where a concern relates to a client’s work, Silver Bird will also tell the client’s agreed contact, sharing only what is necessary.

8. Responsibilities, Breaches and Review

Alexis Assimacopoulos, Managing Director – Owns this policy; carries out supplier checks; handles concerns and reports suspected offences to the police

Leah Assimacopoulos, Director – Supports reviews and keeps supplier records

Associates and subcontractors – Comply with this policy and report any concern straight away

Silver Bird will end its relationship with any supplier, associate or subcontractor that breaches this policy and does not put it right and will report suspected offences to the police.

The directors review this policy every two years, and sooner if the law, Silver Bird’s business or its supply chain changes.

Approval

Approved by

Alexis Assimacopoulos, Managing Director, for and on behalf of Silver Bird Consultancy Services Ltd

Approved October 19, 2026

Next review October 19, 2028