By working with us you agree to our terms; being:
1) Introduction
Cyber Defence Service Ltd (“CDS”, “we”, “us”) is committed to protecting and respecting human rights and has a zero-tolerance approach to modern slavery and human trafficking in all its forms. This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps we have taken, and continue to take, to prevent modern slavery and human trafficking within our business and our supply chains.
2) Our organisation structure, business and supply chains
Structure
CDS is a UK private limited company (Ltd). We have two majority shareholders. We comply with all legislation and governance that a Limited company is required to do.
Business
We specialise in the cyber, radio-frequency, and electromagnetic environments. We support organisations across sectors including national defence, law enforcement, and public and private sector clients by developing secure platforms and methodologies that connect advanced hardware to secure cloud-based software systems, and by providing cyber and systems-related services (including intelligence and systems engineering).
Supply chains
Our supply chains support both our operational delivery and our internal business functions. They include (but are not limited to):
- Technology and equipment: electronics such as computers, audio-visual equipment, phones and related peripherals.
- Services supporting delivery: specialist professional services (including cyber and systems-related support), and (where required) contractor and agency labour.
- Business operations: supplies, furniture and stationery, books and printing, travel services, and food/catering supplies.
Because some categories (particularly electronics and certain services) can involve complex, multi-tier and international manufacturing or labour inputs, we recognise the need for proportionate, risk-based due diligence.
3) Policies relating to modern slavery and human trafficking
Our policy position is underpinned by:
- Our commitment to act ethically and with integrity in all relationships and to use reasonable endeavours to prevent modern slavery and human trafficking within our direct operations and wider sphere of influence.
- Human Resources policies that set out workplace rights and expectations.
- Right-to-work checks for all new employees.
- The use of specified and reliable agencies/partners where we engage agency workers or contractors.
- A whistleblowing approach aligned to the Public Interest Disclosure Act 1998, enabling concerns about unlawful or unethical practice to be raised and investigated.
We expect suppliers, contractors, and partners working with or for CDS to uphold equivalent standards and to raise concerns promptly where risks are suspected.
4) Due diligence processes in our business and supply chains
Our due diligence is proportionate to the nature of the supplier relationship and the risk profile of the goods/services being procured. Our approach includes:
Supplier onboarding and assessment
- Segmentation of suppliers by category and risk (e.g., labour provision, electronics/technology, professional services, facilities/operations).
- Risk-based checks prior to onboarding (for example: supplier identity checks; review of publicly available information; and confirmation of relevant policies/controls where appropriate).
- Clear expectations at engagement stage that modern slavery and human trafficking are prohibited.
Contracting and ongoing management
- Where appropriate, contractual and/or purchase terms that require compliance with applicable law and prohibit modern slavery and human trafficking.
- Ongoing supplier relationship management that encourages transparency and escalation of concerns.
- Where proportionate, use of third-party verification/assurance activities (including Sustain verifications of relevant direct suppliers as we develop our supply-chain monitoring approach).
Recruitment and labour practices
- Right-to-work checks and applicant vetting.
- Use of specified/reliable agencies where contingent labour is required.
- Where required sponsored vetting for SC (Security Check) and DV (Developed Vetting).
Escalation and remediation
Where a modern slavery concern is identified, we will:
- assess the allegation and associated risk promptly;
- work with the supplier/partner to require corrective action within an agreed timeframe;
- consider suspension/termination of the relationship where risk cannot be satisfactorily mitigated; and
- where appropriate, report concerns to relevant authorities.
5) Risk assessment: where risk may exist and how we manage it
We recognise that modern slavery risks can exist across many sectors and supply chains, and that exploitation can be difficult to detect. We consider the following areas more likely to present elevated risk:
- Electronics/technology supply chains (due to multi-tier manufacturing and global sourcing).
- Contractor/agency labour (risk of worker exploitation, coercion, unfair recruitment fees, or withheld documentation).
- Facilities/operations-related services (e.g., catering, travel services, and other outsourced services), depending on the provider’s labour model and subcontracting.
Controls and mitigations include:
- Using specified and reliable agencies/partners for labour supply.
- Vetting applicants and verifying identity and qualifications.
- Setting expectations with suppliers/partners, and adopting proportionate due diligence and monitoring.
- Working collaboratively with partner organisations and suppliers to share information and mitigate risks.
6) Effectiveness and performance indicators (KPIs)
To assess the effectiveness of our approach, CDS tracks and reviews performance indicators that we consider appropriate for our size and operating model, our indicators include:
- 100% completion of right-to-work checks for all new employees.
- % of new suppliers risk-screened at onboarding (with enhanced checks for higher-risk categories).
- % of contingent labour engaged via specified/reliable agencies/partners.
- Number of modern slavery concerns raised (including whistleblowing) and time to triage/close.
- Coverage of supplier assurance activities (e.g., number of relevant direct suppliers subject to verification/assurance in the period).
- Training completion rates (see section 7).
We review outcomes at management level and use the results to improve our controls and supplier engagement.
7) Training and capacity building
We are committed to researching, teaching, and raising awareness on modern slavery issues. Our training and awareness approach is designed to be proportionate and practical, and includes:
- Staff awareness: modern slavery and reporting expectations communicated through induction and internal guidance.
- Role-based strengthening: enhanced guidance for staff involved in recruitment, supplier engagement and procurement activity.
- Reporting: clear routes for staff to raise concerns (including whistleblowing), with assurance that concerns will be handled appropriately.
We will continue to improve our capability and refresh training/awareness materials to reflect evolving risks and best practice.
8) Overseas employment practices
While we have limited HR resources, we work hard to mitigate any risks regarding our employment process and we vet every applicant to ensure they are who they say they are and that they hold the relevant qualifications for the role. We will continue our work on improving this continually.
9) Governance, approval and publication
This statement was approved by the Board of Directors of Cyber Defence Service Ltd on 23rd of January 2026 and is signed by a Director.
Name: Ian Strachan
Title: Director, Cyber Defence Service Ltd
Updated: 23.01.2026
This statement is published on our UK website and will be reviewed and updated annually.