1. Introduction
Accipio Ltd (trading as Aicura) is committed to preventing modern slavery and human trafficking in all aspects of its business operations and supply chains. We recognise our responsibility to uphold ethical standards and respect human rights in accordance with the UK Modern Slavery Act 2015.
This statement sets out the actions we have taken, and continue to take, to identify, mitigate, and prevent modern slavery risks.
2. Our Organisation and Supply Chains
Accipio Ltd (trading as Aicura) is a UK-based provider of digital learning, workforce development, and technology-enabled consultancy services. We specialise in the design, implementation, and support of learning platforms (including Moodle and Totara), alongside digital transformation and capability development services.
We operate primarily in the United Kingdom and work with clients across the public, private, and third sectors.
Our supply chains primarily include:
- Cloud hosting and SaaS providers
- Learning technology vendors
- Professional services contractors and associates
- Business support services (e.g. IT, finance, legal)
Given the nature of our services, our supply chain is largely knowledge-based; however, we recognise that elements of global technology supply chains may present indirect risks.
3. Policies Relating to Modern Slavery
We maintain a number of internal policies that support our commitment to preventing modern slavery, including:
- Code of Conduct
- Supplier and Procurement Policy
- Whistleblowing Policy
- Equality, Diversity and Inclusion Policy
These policies set expectations for ethical behaviour, ensure compliance with applicable laws, and provide clear processes for raising concerns.
4. Risk Assessment: Areas of Higher Risk
We assess modern slavery risk across both our operations and supply chains. While our direct operations are considered low risk due to the professional nature of our work, we recognise potential higher-risk areas may include:
- Global supply chains linked to technology hardware and infrastructure
- Third-party service providers operating in higher-risk jurisdictions
- Indirect suppliers within multi-tier supply chains
We take a proportionate, risk-based approach to identifying and managing these areas.
5. Due Diligence Processes
To manage and prevent modern slavery risks, we implement the following due diligence measures:
- Risk-based supplier assessment during onboarding
- Preference for reputable, established suppliers with clear ethical standards
- Inclusion of contractual clauses requiring compliance with modern slavery legislation
- Ongoing review of supplier relationships, particularly where risk factors change
- Oversight of subcontractors and consultants engaged by the business
Where appropriate, we may request supplier assurances or evidence of their own policies and controls.
6. Training and Capacity Building
We ensure that relevant staff are aware of modern slavery risks and understand their responsibilities. This includes:
- Raising awareness of modern slavery indicators and risks
- Ensuring staff know how to escalate concerns
- Embedding ethical considerations into procurement and supplier management
As the organisation grows, we will continue to formalise and expand training and awareness activities.
7. Key Performance Indicators (KPIs)
We monitor our effectiveness in addressing modern slavery risks through proportionate measures, including:
- Percentage of suppliers assessed for modern slavery risk
- Inclusion of modern slavery clauses in supplier contracts
- Number of staff made aware of modern slavery policies and reporting processes
- Any reported concerns or incidents and their resolution
- Given the size and nature of our organisation, we take a pragmatic approach to KPI tracking while ensuring continuous improvement.
8. Reporting Concerns
We encourage employees, contractors, suppliers, and stakeholders to report any concerns related to modern slavery or unethical practices. Concerns can be raised confidentially and will be taken seriously and investigated appropriately.
9. Continuous Improvement
We are committed to continuously improving our approach by:
- Regularly reviewing policies and procedures
- Enhancing supplier due diligence as the business grows
- Strengthening awareness and training initiatives
- Monitoring evolving risks within our supply chain
10. Approval
This statement has been approved by the directors of Accipio Ltd (trading as Aicura) and will be reviewed annually.
Signed:
Sascha Benson-Cooper
Director
Accipio Ltd (trading as Aicura)
Financial Year: 2025–2026