Modern Slavery Statement

1. Introduction

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2026.

Infinity Cloud System LIMITED ("we," "us," or "our") is committed to preventing slavery and human trafficking in our business operations and supply chains. We have zero tolerance for modern slavery in any form.

2. Our Organization

We are a UK-based IT consultancy firm providing professional services including IT infrastructure audits, performance optimization, cloud migration strategy, and technical consulting services to businesses primarily in the United Kingdom and Europe.

3. Our Business and Supply Chains

3.1 Our Business Structure

Our business operations include:

• IT consultancy and advisory services
• Technical audits and assessments
• Performance optimization services
• Cloud migration and strategy consulting
• Quality assurance reviews
• Digital transformation consulting

3.2 Our Supply Chains

Our supply chains are relatively simple and primarily consist of:

• Technology Services: Cloud hosting providers, software vendors, payment processors (Stripe)
• Professional Services: Subcontractors and specialist consultants (when required)
• Office Services: Office equipment, utilities, telecommunications
• Professional Advisors: Legal, accounting, and compliance services

The majority of our suppliers are established, reputable companies based in the United Kingdom and European Union, operating in low-risk sectors.

4. Policies and Procedures

4.1 Our Commitment

We are committed to:

• Ensuring there is no modern slavery or human trafficking in our business or supply chains
• Acting ethically and with integrity in all our business relationships
• Implementing and enforcing effective systems and controls
• Conducting business in a socially responsible manner

4.2 Code of Conduct

Our Code of Conduct reflects our commitment to acting ethically and with integrity. We expect all employees, contractors, and business partners to:

• Comply with all applicable laws and regulations
• Treat all individuals with dignity and respect
• Report any concerns about modern slavery or human trafficking
• Cooperate with investigations and remediation efforts

4.3 Recruitment and Employment

We ensure that:

• All employees have the right to work in the UK
• Employment is freely chosen and voluntary
• Employees are paid at least the National Minimum Wage or National Living Wage
• Working conditions meet or exceed legal requirements
• No recruitment fees are charged to workers
• Employees are free to leave employment with appropriate notice

4.4 Whistleblowing Policy

We encourage employees and stakeholders to report any concerns about modern slavery or human trafficking through our Speak Up Policy. All reports are treated confidentially and investigated thoroughly.

5. Due Diligence and Risk Assessment

5.1 Risk Assessment

We assess the risk of modern slavery in our business and supply chains by considering:

• Sector Risk: Industries known for higher modern slavery risks
• Geographic Risk: Countries with weak labor protections or high prevalence of forced labor
• Product/Service Risk: Goods or services with complex supply chains
• Business Partner Risk: Third-party labor providers, subcontractors

5.2 Our Risk Profile

We consider our overall risk of modern slavery to be low because:

• We operate primarily in the professional services sector
• Our supply chains are short and transparent
• The majority of our suppliers are based in the UK and EU
• We engage with established, reputable companies
• We do not manufacture physical products or use extensive manual labor

5.3 Supplier Due Diligence

When engaging new suppliers, we:

• Assess their compliance with modern slavery legislation
• Review their own modern slavery statements (where applicable)
• Include anti-slavery clauses in contracts
• Reserve the right to audit supplier practices
• Terminate relationships with non-compliant suppliers

6. Supplier Standards and Expectations

We expect all suppliers and business partners to:

• Comply with the Modern Slavery Act 2015 and all applicable laws
• Ensure their own supply chains are free from modern slavery
• Treat workers fairly and with respect
• Pay workers at least the minimum wage applicable in their jurisdiction
• Provide safe working conditions
• Not use forced, bonded, or compulsory labor
• Not use child labor
• Allow workers freedom of movement and association
• Cooperate with audits and investigations

Failure to meet these standards may result in termination of the business relationship.

7. Training and Awareness

We provide training and awareness programs to ensure that:

• Employees understand what modern slavery is
• Staff can recognize signs of modern slavery and human trafficking
• Employees know how to report concerns
• Those involved in procurement understand their responsibilities
• Management is equipped to handle reports and take appropriate action

Training is provided to relevant staff upon joining and refreshed annually.

8. Effectiveness and Key Performance Indicators

We measure the effectiveness of our efforts to prevent modern slavery through:

• Supplier Compliance: Percentage of suppliers with modern slavery policies or statements
• Training Completion: Number of employees completing modern slavery awareness training
• Incident Reports: Number of concerns raised and actions taken
• Contract Compliance: Inclusion of anti-slavery clauses in new supplier contracts
• Risk Assessments: Regular reviews of supply chain risks

8.1 Reporting Period Performance

For the financial year ending 2026:

• No incidents of modern slavery were identified in our business or supply chains
• All relevant staff completed modern slavery awareness training
• Anti-slavery clauses were included in all new supplier contracts
• Supply chain risk assessment was conducted and documented

9. Reporting Concerns

If you suspect modern slavery or human trafficking in our business or supply chains, please report it:

10. Continuous Improvement

We are committed to continuous improvement in our approach to preventing modern slavery. Our plans include:

• Enhancing supplier due diligence procedures
• Developing more comprehensive risk assessment tools
• Expanding training programs to cover emerging risks
• Strengthening monitoring and audit processes
• Collaborating with industry peers to share best practices
• Regularly reviewing and updating this statement

11. Governance and Accountability

Responsibility for our modern slavery program lies with senior management, who:

• Approve this statement annually
• Oversee implementation of policies and procedures
• Review reports of concerns and remediation actions
• Ensure adequate resources are allocated to prevent modern slavery
• Monitor key performance indicators

12. Statement Review

This statement is reviewed and updated annually. The next review is scheduled for April 2027.

Previous statements are available upon request.

13. Approval and Sign-Off

This statement has been approved by the board of directors of Infinity Cloud System LIMITED.

14. Contact Information

For questions about this Modern Slavery Statement, please contact: