PART 1
Modern Slavery and Human Trafficking Policy
1. Purpose
Abilia is committed to conducting business ethically, responsibly and with integrity. We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, bonded labour, servitude and child labour in our own operations and supply chains. This policy supports Abilia's commitment to human rights, responsible sourcing and proportionate risk management.
2. Scope
This policy applies to:
- All employees, directors and officers of Abilia,
- Temporary workers, agency workers, contractors and consultants,
- Suppliers, manufacturers, distributors, logistics providers and other business partners, and
- Any person or organisation acting on behalf of Abilia.
3. Policy commitments
Abilia will:
- Comply with applicable modern slavery and human trafficking legislation, including the UK Modern Slavery Act 2015,
- Seek to prevent modern slavery and human trafficking in our business and supply chains,
- Promote ethical employment practices, freely chosen employment and fair working conditions,
- Identify and assess modern slavery risks using a proportionate, risk-based approach,
- Consider modern slavery risk in supplier selection, onboarding, contracting and ongoing supplier management,
- Expect suppliers to comply with applicable labour laws and internationally recognised human rights standards,
- Provide appropriate reporting channels and investigate concerns in a timely and fair manner, and
- Take proportionate corrective or remedial action where concerns or non-compliance are identified.
4. Roles and responsibilities
Management
- Approve and oversee Abilia’s approach to modern slavery.
- Ensure appropriate responsibilities, resources and governance are in place.
- Review the annual Modern Slavery Statement and relevant performance information.
Sourcing and supplier owners
- Consider modern slavery risks when selecting and reviewing suppliers.
- Obtain relevant information and assurances based on the supplier’s risk profile.
- Escalate concerns and support corrective action or remediation.
- Maintain appropriate records of risk assessments, decisions and follow-up actions.
Employees and contractors
- Act with integrity and follow this policy and related procedures.
- Remain alert to indicators of exploitation or unethical labour practices.
- Promptly report concerns through the available reporting channels.
5. Supplier expectations
Abilia expects suppliers and business partners to:
- Prohibit forced labour, human trafficking, bonded labour and child labour.
- Ensure employment is freely chosen and workers may leave employment in accordance with applicable law.
- Provide safe and lawful working conditions.
- Comply with applicable employment, wage, working time and immigration laws.
- Maintain accessible grievance and reporting mechanisms.
- Cooperate with proportionate due diligence, audits or information requests; and
- Address identified issues and support appropriate remediation.
Where appropriate, these expectations may be incorporated into supplier contracts, the Supplier Code of Conduct, tender documentation or corrective action plans.
6. Risk assessment and due diligence
Modern slavery risk will be assessed proportionately. Relevant factors may include:
- CSR risks relating to raw material extraction.
- CSR risks relating to processing activities.
- CSR risks relating to assembly and final manufacturing.
- Manufacturing and assembly location risks.
- Complexity and transparency of the supply chain.
- Previous concerns, audit findings or adverse information.
- The criticality and value of the supplier relationship.
For the purposes of this policy, CSR risks include Human & Workers' Rights, Environmental Protection and Business Ethics.
Higher-risk suppliers or activities may be subject to enhanced review, additional contractual controls, evidence requests, corrective action plans or other monitoring measures.
7. Reporting and non-retaliation
Employees and third parties are encouraged to raise concerns through their manager, Human Resources, the designated compliance contact or Abilia’s whistleblowing channel. Reports will be handled as confidentially and as reasonably as possible. Abilia does not tolerate retaliation against anyone who raises a concern in good faith.
8. Investigation and remediation
Abilia will assess reported concerns and determine proportionate action. This may include investigation, engagement with the supplier, corrective action, enhanced monitoring, suspension or termination of the relationship, and referral to relevant authorities where appropriate. The priority will be to avoid increasing harm to affected workers and to support appropriate remediation.
9. Training, monitoring and review
Relevant employees, particularly those working in sourcing, supplier management, operations and leadership, will receive information or training appropriate to their responsibilities.
Implementation of this policy will be monitored through risk assessments, due diligence activity, reported concerns, corrective actions and other relevant indicators. The policy will be reviewed at least annually and updated when necessary.
10. Related documents
- Code of Conduct (ID 17480)
- Supplier Code of Conduct (ID 17374)
- Whistleblowing Policy (ID 17479)
- Sustainability Policy (ID 17513)
- Annual Modern Slavery Statement
PART 2
Modern Slavery Statement 2026
Pursuant to section 54 of the UK Modern Slavery Act 2015
1. Introduction
This statement is made by Abilia Ltd pursuant to section 54 of the UK Modern Slavery Act 2015. It describes the steps taken during the financial year ending 31 December 2026 to prevent modern slavery and human trafficking in our business operations and supply chains.
Abilia Ltd is committed to conducting business ethically, responsibly and with integrity. We have a zero-tolerance approach to modern slavery and human trafficking and expect equivalent standards from our business partners.
2. Our business and supply chain
Abilia develops and provides assistive technology solutions that support people with disabilities in everyday life. Abilia Ltd operates in the United Kingdom as part of the Abilia Group, which has operations across Sweden, Norway, the United Kingdom, the Netherlands and other markets.
Our supply chain includes contract manufacturers, electronics and component suppliers, logistics providers, technology providers and professional service providers. Suppliers operate in multiple jurisdictions and have differing risk profiles. We recognise that risks may be greater in complex, labour-intensive or less transparent parts of global supply chains.
3. Policies and governance
Our governance framework is supported by the following policies and processes:
- Modern Slavery and Human Trafficking Policy
- Code of Conduct (ID 17480)
- Supplier Code of Conduct (ID 17374)
- Whistleblowing Policy (ID 17479)
- Sustainability Policy (ID 17513)
The Management Team is responsible for approving this statement. Relevant management functions support implementation, while sourcing and supplier owners apply due diligence within their areas of responsibility.
4. Due diligence processes
Abilia applies proportionate due diligence within its operations and supply chain. Activities include, where relevant:
- Supplier onboarding and screening,
- Risk-based supplier assessments,
- Review of supplier policies, certifications or other supporting evidence,
- Contractual expectations relating to ethical conduct and legal compliance,
- Use of the UK Government Modern Slavery Assessment Tool where required for NHS sourcing,
- Follow-up of concerns, adverse information or identified control gaps, and
- Ongoing monitoring for selected suppliers based on risk.
5. Risk assessment and management
Our risk assessment considers factors including supplier location, sector, products and materials, use of vulnerable labour, supply-chain complexity, available evidence and previous concerns. Based on this assessment, suppliers or activities may be categorised for standard or enhanced due diligence.
Where a material concern is identified, Abilia will assess the facts, engage relevant stakeholders and determine proportionate corrective action. Our approach will seek to protect affected workers and avoid actions that may unintentionally increase harm.
6. Training and awareness
Abilia promotes awareness of ethical business conduct and responsible sourcing. Relevant employees, particularly those involved in sourcing, supplier management, operations and leadership, will receive information or training appropriate to their responsibilities.
7. Measuring effectiveness
During the reporting period and going forward, Abilia will monitor the effectiveness of its approach using proportionate indicators, including:
- Completion of the Modern Slavery Assessment Tool and maintenance of the required NHS tender readiness level,
- Number or proportion of relevant suppliers screened or risk-assessed,
- Number of higher-risk suppliers subject to enhanced due diligence,
- Completion of relevant employee training or awareness activity,
- Modern slavery concerns reported and investigated, and
- Corrective actions agreed, completed and overdue.
Results will be reviewed periodically and used to improve our controls. Public reporting will remain proportionate and will protect confidential or sensitive information.
8. Progress during 2026
During 2026, Abilia has focused on establishing and strengthening its governance and tender readiness for NHS requirements.
9. Priorities for the next reporting period
- Embed the Modern Slavery and Human Trafficking Policy across relevant functions.
- Maintain and annually update the Modern Slavery Assessment Tool.
- Further develop supplier risk segmentation and enhanced due diligence.
- Strengthen contractual expectations and supplier follow-up where appropriate.
- Provide targeted awareness or training for relevant employees.
- Review performance indicators and report progress to management and the Board.
