Modern Slavery Statement

Introduction

This statement sets out the steps Pontiro Ltd has taken, and the position it holds, in relation to modern slavery and human trafficking in its operations and supply chains.

Pontiro is not required to publish a statement under section 54 of the Modern Slavery Act 2015, as its annual turnover is below the £36 million threshold. This statement is published voluntarily.

Organisation

Pontiro Ltd is a private company registered in England and Wales (company number 16083251), with its registered office at Alacrity House, Newport NP20 1HG, United Kingdom.

Pontiro provides independent evaluation of healthcare artificial intelligence systems and data anonymisation services for medical research. The team is small and based primarily in the United Kingdom, consisting of employees and contracted specialists.

Business and supply chains

Pontiro operates predominantly in the digital domain and its supply chain is limited. The main categories of supplier are:

Cloud hosting and infrastructure providers.
Software-as-a-service tools, including productivity, analytics, and development tooling.
Professional services such as accountancy, legal, and recruitment support.
Occasional procurement of office equipment and consumables.

Pontiro does not manufacture physical goods and does not operate a multi-tier supplier base.

Policies and expectations

Pontiro expects suppliers, contractors, and partners to comply with applicable law, including the Modern Slavery Act 2015 in the United Kingdom.

Engagement terms with employees and contractors are written and transparent. Pontiro pays at or above the relevant statutory minimum, conducts right-to-work checks for UK employees, and recruits through established channels.

Due diligence

Due diligence steps currently in place include:

Engaging established suppliers and platform vendors that publish their own modern slavery statements where applicable.
Written contracts with employees, contractors, and clients that set out expectations of lawful conduct.
UK-based recruitment channels with right-to-work checks for employees.

Risk assessment

Pontiro is a small, UK-based provider of digital services with no physical manufacturing. Direct exposure to modern slavery and human trafficking risk is assessed as low. Residual risk exists in the wider technology supply chain, particularly in upstream hardware manufacturing, and is mitigated by sourcing through established vendors.

Effectiveness

Given the size of Pontiro and the limited scope of its supply chain, no formal performance indicators are currently in place. The effectiveness of the steps set out in this statement is reviewed by the Board of Directors at least annually when the statement is renewed.

To date, no instances of modern slavery or human trafficking have been identified or reported in Pontiro's operations or supply chain.

Training

Pontiro does not currently operate a formal modern slavery training programme. This position will be reviewed as the organisation grows.

Reporting concerns

Suspected modern slavery or human trafficking in connection with Pontiro's operations or supply chain can be reported in confidence to [email protected].

Approval

This statement was approved on 1 June 2026 by:

Lewis Bowen
CEO, Pontiro Ltd

Modern Slavery and Human Trafficking Statement