MSA Group Limited

Modern Slavery and Human Trafficking Statement

Financial Year: 1 April 2025 – 31 March 2026

Introduction

This statement is made in accordance with Section 54(1) of the UK Modern Slavery Act 2015. It describes the actions taken by MSA Group Limited during the financial year ending 31 March 2026 to prevent modern slavery and human trafficking within our business operations and supply chains.

MSA Group Limited is firmly committed to ensuring that modern slavery, human trafficking, forced labour and any other forms of exploitation have no place in our organisation or among those who supply to us. We recognise that every business, regardless of size or sector, has a responsibility to take a proactive stance against these crimes. Our zero-tolerance policy applies to all areas of our business and to every organisation that we engage with, whether as suppliers, service providers or partners. We believe that ethical conduct and respect for human rights are fundamental to sustainable success and to the integrity of our work.

Organisation Structure and Business Model

MSA Group Limited is a privately owned UK-based professional services company, registered under Company Number 16277238, and operating from 3rd Floor, 86–90 Paul Street, London, EC2A 4NE. The company employs a total of six people. Our structure is deliberately streamlined, with all employees and business functions located within the United Kingdom. We do not operate overseas offices or subsidiaries, nor do we outsource services to offshore entities.

Our business model focuses on delivering professional consulting and technology development services to UK-based clients. We maintain a small and carefully managed supply chain that supports our office operations, IT systems, and professional services. All suppliers are based in the United Kingdom and are selected for their reliability, compliance with UK law, and shared ethical values.

Because our operations and supplier network are entirely UK-based, and because we do not engage in high-risk sectors such as manufacturing, agriculture, or construction, the risk of modern slavery within our direct operations is considered low. However, we remain vigilant and recognise that exploitation can occur in unexpected parts of the economy, including in low-risk industries. As such, we remain committed to continuously monitoring, reviewing, and improving our systems to prevent any risk of human rights abuse.

Policies in Relation to Modern Slavery

MSA Group Limited has adopted a suite of policies that collectively express our commitment to ethical working practices and the eradication of modern slavery. These policies include our Anti-Slavery and Human Trafficking Policy, our Code of Conduct and Ethics, our Whistleblowing Policy, and our Supplier Code of Conduct.

Our Anti-Slavery and Human Trafficking Policy outlines our zero-tolerance stance and sets clear expectations for employees, suppliers, and business partners. It provides practical guidance on recognising potential indicators of modern slavery, defines clear channels for reporting concerns, and establishes a framework for internal investigation and escalation. All staff are required to familiarise themselves with this policy, and breaches are treated as serious disciplinary matters.

The company’s Code of Conduct reinforces our expectation that all employees and business partners act with honesty, fairness, and respect for human rights at all times. This code forms part of our culture and is embedded in our recruitment, training, and performance management processes. We expect all colleagues to behave with integrity and to uphold the dignity and rights of everyone they interact with.

Our Whistleblowing Policy ensures that employees and external parties can raise concerns about unethical behaviour, exploitation, or any breach of our standards safely and without fear of retaliation. Reports may be made confidentially, and all credible concerns are investigated fully.

We also maintain a Supplier Code of Conduct that sets out clear obligations for our suppliers to comply with all relevant laws, including the Modern Slavery Act 2015. This document requires suppliers to ensure that their own employees, contractors, and supply chains are free from exploitation, coercion, or any form of modern slavery. The company reserves the right to terminate relationships with any supplier found to be acting in breach of these principles.

In addition, our recruitment procedures include robust right-to-work checks for all employees to ensure that every individual working for MSA Group does so voluntarily and legally. We only use reputable recruitment channels, and we do not use agencies that charge recruitment fees to workers or that are not transparent about their practices.

Due Diligence Processes

MSA Group Limited undertakes careful due diligence to identify and mitigate the risk of modern slavery within our operations and supply chain. All new suppliers undergo an initial vetting process before engagement. This involves confirming that the supplier is a legitimate UK-registered entity, reviewing their published Modern Slavery Statement (if applicable), and confirming compliance with our Supplier Code of Conduct. We prioritise working with suppliers who share our commitment to transparency and fair employment practices.

We include anti-slavery and human trafficking clauses in all of our standard contracts and purchase agreements. These clauses oblige suppliers to comply with the Modern Slavery Act and allow MSA Group to audit their compliance or to terminate agreements where breaches are identified. Throughout the financial year 2025–2026, we reviewed our supplier contracts to ensure these provisions were included and clearly understood by all parties.

Our monitoring does not end once suppliers are onboarded. We maintain regular communication with them and remain alert to any changes that could indicate emerging risks. During the year covered by this statement, no instances or suspicions of modern slavery or human trafficking were identified within our business or among our suppliers.

Internally, MSA Group verifies the employment status and right-to-work of all staff members at the point of recruitment. All employees are paid at or above the applicable legal minimum wage, and their working hours and conditions comply fully with UK employment law. The company does not use forced, bonded, or involuntary labour in any form.

If at any time we were to identify potential concerns, we would take immediate steps to investigate and, where necessary, escalate the matter to the relevant authorities. We are prepared to suspend or terminate any relationship with a supplier or partner who fails to meet our ethical standards.

Risk Assessment and Management

Based on our size, business model, and operational structure, MSA Group Limited considers the overall risk of modern slavery in its operations to be low. Nonetheless, we understand that risk cannot be entirely eliminated and that complacency can create vulnerability. We therefore carry out annual reviews of our operations and supply chain to assess potential exposure to exploitation.

This risk assessment takes into account factors such as the type of goods and services we procure, the geographic location of suppliers, the sectors in which they operate, and the nature of the work they perform. Our most recent assessment confirmed that none of our suppliers operate in sectors commonly associated with forced or exploitative labour.

While our direct suppliers pose a low risk, we also consider potential indirect risks—for example, the possibility that cleaning or maintenance contractors used by building management could employ vulnerable workers. We engage only with facilities providers who uphold good labour standards and remain prepared to raise any concerns should they arise.

We recognise that our low-risk status is not static. As we grow and diversify our operations, our exposure to modern slavery risks may evolve. To address this, we have committed to reviewing our risk management framework annually and whenever there is a significant change in our supplier base or business model. This ensures that our mitigation strategies remain proportionate and effective.

Training and Awareness

Education is central to preventing modern slavery. During the 2025–2026 financial year, all MSA Group employees completed training on modern slavery awareness. This training helped staff to understand the different forms that exploitation can take, recognise the warning signs, and understand the steps to take if they suspect wrongdoing.

The training also reinforces the company’s ethical obligations under the Modern Slavery Act and the importance of speaking up. Employees were encouraged to reflect on how modern slavery might affect everyday business decisions and how to ensure that human rights remain a consideration in procurement, recruitment, and partnership activities.

Modern slavery awareness is also embedded in our induction programme for new employees. Each new starter receives information about our Anti-Slavery and Human Trafficking Policy, Whistleblowing Policy, and reporting procedures. Regular refresher training sessions will continue to take place annually to ensure that awareness remains high.

We plan to expand our training programme in the next year by introducing scenario-based exercises, practical examples, and potentially external guest speakers to share insight into real-world cases. Our goal is to maintain a culture where all employees feel responsible for identifying and preventing exploitation.

Planned Actions for 2025–2026

MSA Group Limited remains committed to continuous improvement in its efforts to combat modern slavery. Over the next twelve months, we will strengthen our practices by deepening engagement with suppliers and formalising our due diligence approach.

We will introduce a modern slavery questionnaire to be completed by all new suppliers, allowing us to gather structured information about their workforce practices and supply chain management. Existing suppliers will be asked to reaffirm their compliance with our Supplier Code of Conduct and our anti-slavery expectations.

We will also conduct a formal review of our internal policies, including the Anti-Slavery and Human Trafficking Policy and the Whistleblowing Policy, to ensure they remain current with legislative updates and best practice guidance. Where appropriate, we will expand these policies to include further detail on responsibilities, escalation procedures, and governance.

In addition, we will review our internal reporting and risk monitoring processes to ensure that any issues identified are recorded and addressed effectively. The company will continue to monitor legislative developments, particularly any changes proposed to strengthen the Modern Slavery Act or its enforcement mechanisms.

We also intend to make our Modern Slavery Statement publicly available through the Government’s online Modern Slavery Statement Registry, even though this is currently voluntary. This demonstrates transparency and reinforces our accountability to stakeholders and the public.

Finally, we will maintain regular dialogue between management and staff about ethical practices and continue to promote a culture of responsibility, vigilance, and respect for human rights across the organisation.

Approval and Sign-Off

This Modern Slavery and Human Trafficking Statement has been approved by the Board of Directors of MSA Group Limited and signed by the Managing Director in accordance with Section 54 of the Modern Slavery Act 2015.

MSA Group Limited remains fully committed to playing its part in the elimination of modern slavery and human trafficking. We will continue to monitor, evaluate, and improve our practices to ensure that our company and those with whom we work uphold the highest standards of integrity and human rights.

Signed,
Sabir Ahmed
Managing Director
MSA Group Limited
Date: 1 July 2026