Year ending June 2025
Adaptive Group Technology Ltd
This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by Adaptive Group Technology Ltd for the period ending June 2025 to prevent modern slavery and human trafficking in its business operations and supply chains.
Introduction
This statement covers Adaptive Group Technology Ltd, including Adaptive Financial Consulting Ltd, Adaptive Consulting SLU, Technologies Adaptive, Adaptive Financial Consulting Inc., Adaptive Brasil Servicos de Tecnologia Ltda, and AFC Technology Corp.
Adaptive is committed to being a great place to work but this can only be achieved by looking at the standards we set internally and the standards we require of our suppliers. We are an equal opportunities employer and are committed to ensuring a respectful and non-discriminatory working environment for our staff.
We have recruitment and people management processes that ensure that all prospective and current staff are entitled to work in the relevant location. We demand an ethical approach from all recruitment suppliers in order to safeguard staff and prospective staff from coercion and/or abuse.
We will not engage with or continue to maintain relationships with any organisation in the UK or abroad, which knowingly supports or is found to be engaged in slavery, servitude, and/or forced or compulsory labour.
Business and Operational Structure
The nature of our business means that we class ourselves as being at low risk of modern slavery in our operations and supply chain. Our supply chains are relatively limited and include IT, data hosting and communications infrastructure, software and data service providers, office space leasing, facilities and travel services, and we generally procure goods and services from large, well-established organisations with their own public commitments to the Modern Slavery Act.
Adaptive maintains staff policies with regard to anti-harassment and bullying, whistleblowing, health and safety, anti-bribery and corruption, and equal opportunities.
Adaptive operates in 6 countries, with 5 of our offices managed by a Local Director; United Kingdom, Spain, Canada, United States of America, and the Philippines. The details of our 6th office, our Brazilian entity, are to be finalised in due course.
Governance
Our ESG (Environmental, Social & Governance) Committee governs our approach to avoiding modern slavery, with each Local Director responsible for the day-to-day implementation. Our COO leads the ESG Committee and is ultimately responsible.
Due Diligence
During the year ending June 2025, we noted that our onboarding processes did not specifically state that we do not withhold original employee identity documentation; we have updated our policy and process to be more explicit in this regard. We have further updated these policies and processes to prompt/enable our team to act if a candidate advises that their documentation is being withheld by a third party.
Assessment and validation of new supplier operations with regard to modern slavery and human trafficking is now being integrated into our updated supplier onboarding process.
All staff wages are paid into a bank account in their name.
Responsible Recruitment
We make little use of agencies and the like for our recruitment and so our exposure in this regard is limited. As part of the onboarding process of any agency we work with, we specifically ask about responsible and ethical recruitment; we ask about bonded labour, retention of identity documents, and any charges for candidates associated with their engagement by Adaptive.
The majority of our recruitment is direct – i.e. no third party.
We supply all worker agreements to the individual directly (i.e. not via the agency or third-party) and our HR team contacts the worker directly to discuss the agreement and to answer any questions that they might have.
Training and Awareness
Given the low risk profile of the industry we work in, in addition to our negotiations with recruitment agencies, and supplier due diligence, we have not undertaken specific training or awareness for staff in general. Our ESG are considering our needs regarding training and awareness for the 25/26 year.
To date, we have not found any evidence within our supply chains that would violate modern slavery and human trafficking laws or otherwise contravene Adaptive’s values and commitments regarding human rights.
This statement has been approved by Adaptive’s Board of Directors and signed by the COO.