Modern Slavery and Human Trafficking Policy
Last reviewed: September 2026
Our Commitment
NeuroInclusion Works Ltd (“NIW”) is committed to conducting its business ethically and responsibly and to preventing modern slavery and human trafficking within our operations and, so far as reasonably practicable, within our supply chain.
We do not tolerate slavery, servitude, forced or compulsory labour, human trafficking or other forms of exploitation.
Our business
NIW provides specialist employment and workplace services, with a particular focus on supporting neurodivergent people and inclusive employment.
Our activities are predominantly professional and service based. Our supply chain principally consists of providers of professional services, technology and software, business services, venues and other services required to operate and deliver our programmes.
Given the nature of our activities and supply chain, we consider the risk of modern slavery occurring directly within our business to be relatively low. We nevertheless recognise that modern slavery can occur in any sector and that some goods and services purchased by NIW may have more complex supply chains beyond our direct suppliers.
We therefore take a proportionate and risk-based approach to identifying and responding to modern slavery risks.
Employment and recruitment
NIW seeks to ensure that everyone working directly for the company does so freely and under transparent terms.
Our employment and recruitment practices include appropriate pre-employment checks, including verification of identity and the right to work in the UK where required. Employees are provided with written terms setting out the principal conditions of their employment, including remuneration.
NIW will not knowingly:
employ or engage anyone who is being forced or coerced to work;
retain an individual's passport, identity documents or other personal documents as a condition of employment;
require an individual to pay recruitment fees to NIW in order to obtain employment;
use threats, intimidation or coercion to prevent someone from leaving employment; or
participate in arrangements intended to facilitate forced labour or human trafficking.
We recognise that particular care may be required where circumstances suggest that an individual could be vulnerable to exploitation.
Suppliers and contractors
NIW expects its suppliers and contractors to comply with applicable employment, labour and modern slavery legislation.
As a relatively small professional services organisation, NIW does not currently undertake formal supply-chain mapping or routine modern slavery audits of suppliers. We instead apply a proportionate, risk-based approach.
Where circumstances relating to a supplier, contractor, sector or service give us reasonable grounds for concern, we may seek further information or assurances before entering into or continuing the relationship.
Where appropriate to the nature or value of an engagement, NIW may include relevant compliance obligations within contractual arrangements.
A supplier's failure to address a credible modern slavery concern may result in NIW reconsidering or terminating the relationship, taking into account the circumstances, the interests of potentially affected individuals and our contractual obligations.
Identifying and reporting concerns
NIW expects its employees and those working on its behalf to remain alert to potential indications of exploitation.
Concerns may arise where, for example, an individual appears unable to leave their employment freely, has their identity documents controlled by another person, is subject to threats or intimidation, has wages improperly withheld, has incurred excessive recruitment-related debts or appears to have been deceived about the nature or conditions of their work.
Employees and workers are encouraged to report suspected modern slavery or human trafficking promptly to a Director. NIW also maintains a whistleblowing procedure through which relevant concerns can be raised.
We will not subject a person to detrimental treatment for raising a genuine concern in good faith.
Where a credible concern is identified, NIW will consider the appropriate response based on the circumstances. This may include seeking further information, obtaining professional advice, engaging with a client, contractor or supplier, or referring the matter to an appropriate authority.
We recognise that immediately terminating a commercial relationship may not always be the most appropriate response where exploitation is suspected, particularly where doing so could cause further harm to affected individuals.
Responsibility and review
The Director has overall responsibility for NIW's approach to modern slavery and human trafficking.
We keep our approach under review and may introduce additional measures where changes to the nature or scale of our activities, our supply chain, customer requirements or identified risks make them appropriate.
This policy will normally be reviewed annually or earlier where there is a significant change in relevant legislation, guidance, NIW's operations or our risk profile.
Modern Slavery Act 2015
NIW supports the objectives of the Modern Slavery Act 2015.
NIW is currently below the turnover threshold at which a commercial organisation is required under section 54 of the Modern Slavery Act 2015 to publish an annual slavery and human trafficking statement.
We have nevertheless chosen to publish this policy as part of our commitment to ethical and responsible business practices.