Modern Slavery Act Statement
Last updated: December 15, 2024
1. Introduction
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 ("the Act") and sets out the steps that Glasshouse Ltd ("Glasshouse", "we", or "us") has taken, and is continuing to take, to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.
Glasshouse is committed to acting ethically and with integrity in all of our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure that modern slavery, forced labour, and human trafficking are not taking place anywhere within our business or in any of our supply chains.
We have a zero-tolerance approach to modern slavery. We expect the same high standards from all of our contractors, suppliers, and other business partners, and as part of our contracting processes we include specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in servitude, whether adults or children.
2. Our Business
Glasshouse is a UK-based technology company that provides a corporate intelligence and asset discovery platform. Our platform enables organisations to search, analyse, and monitor corporate data sourced from authoritative UK registers including Companies House, HM Land Registry, the Financial Conduct Authority ("FCA") register, and persons with significant control ("PSC") registers.
Our services include corporate data search, entity resolution, risk scoring, graph analysis, ownership mapping, and related analytical tools. These services are provided to businesses, financial institutions, law firms, insolvency practitioners, and other professional services organisations primarily within the United Kingdom.
Glasshouse is incorporated in England and Wales and our principal place of business is in the United Kingdom. We employ a team of engineers, data scientists, and business professionals, all of whom are based in the United Kingdom and work under employment contracts that comply with UK employment law.
3. Our Supply Chains
As a technology company, our supply chains are primarily digital in nature and comprise the following categories:
Cloud Infrastructure and Hosting: We use cloud computing providers for hosting our platform, data storage, and computational resources. Our primary infrastructure providers are established, multinational technology companies with their own modern slavery policies and commitments.
Data Providers: We source corporate and regulatory data from UK government bodies (Companies House, HM Land Registry, the FCA) and licensed third-party data aggregators. These are established public sector organisations and regulated data providers.
Software and Technology Vendors: We procure software licences, development tools, and third-party services from established technology vendors, predominantly based in the United Kingdom, the European Economic Area, and the United States.
Professional Services: We engage legal, audit, accounting, and consulting firms on an as-needed basis. These are regulated professional services firms operating under their own ethical and legal obligations.
A current list of our sub-processors involved in the delivery of our services is available on our Sub-processors page.
4. Our Policies
We operate the following policies that are relevant to our commitment to combating modern slavery:
Anti-Slavery and Human Trafficking Policy: We maintain a dedicated anti-slavery policy which sets out our zero-tolerance approach to modern slavery and the responsibilities of all employees in identifying and reporting concerns.
Whistleblowing Policy: We encourage all employees, contractors, and business partners to report any concerns relating to modern slavery without fear of retaliation. Our whistleblowing procedures provide a confidential reporting mechanism and protect those who raise concerns in good faith.
Recruitment Policy: We conduct eligibility-to-work checks for all employees to safeguard against human trafficking or forced labour. We only use specified, reputable employment agencies and verify that they adhere to the relevant legislation.
Supplier Code of Conduct: We expect all suppliers and business partners to adhere to our Supplier Code of Conduct, which includes specific provisions relating to ethical labour practices, fair working conditions, and compliance with all applicable labour laws.
Code of Ethics: Our Code of Ethics sets out the standards of behaviour expected of all employees and establishes our commitment to ethical business practices, including the prevention of exploitation in all its forms.
5. Due Diligence
We undertake the following due diligence processes in relation to modern slavery:
We assess all new suppliers and business partners for modern slavery risks prior to onboarding and require them to confirm their compliance with the Modern Slavery Act 2015.
We include anti-slavery clauses in our contracts with suppliers, requiring them to confirm that neither they nor anyone connected with their business is involved in modern slavery.
We periodically review our existing supplier relationships to ensure ongoing compliance with our anti-slavery requirements.
We conduct right-to-work checks for all employees and verify identity documentation in accordance with UK Home Office guidance.
We maintain a register of suppliers and conduct periodic risk assessments to identify any areas of concern within our supply chain.
Where concerns are identified through our due diligence processes, we will investigate promptly and, where appropriate, take remedial action, which may include termination of the supplier relationship.
6. Risk Assessment
We consider the risk of modern slavery occurring within our direct operations to be low, given that: (a) all of our employees are based in the United Kingdom and work under UK employment contracts; (b) we operate primarily as a technology platform with a digital workforce; and (c) our recruitment and employment practices comply with UK employment law.
We consider the risk within our supply chains to be low to medium, recognising that: (a) our primary suppliers are established technology companies and public sector bodies with their own anti-slavery commitments; (b) our supply chains are predominantly digital and service-based, rather than involving physical manufacturing or commodity supply; and (c) we do not operate in sectors or geographies typically associated with high modern slavery risk.
Despite the assessed low risk, we remain vigilant and continue to monitor our operations and supply chains for any indicators of modern slavery. We recognise that modern slavery can occur in any sector and any geography, and we do not consider any part of our business to be exempt from scrutiny.
7. Training
We provide awareness training to all employees on the Modern Slavery Act 2015, the indicators of modern slavery and human trafficking, and the steps they should take if they suspect that modern slavery is occurring within our business or supply chains.
Enhanced training is provided to employees who are directly involved in procurement, supplier management, and recruitment, to ensure they are equipped to identify and address modern slavery risks in their day-to-day activities.
Training materials are reviewed and updated annually to reflect any changes in legislation, guidance, or best practice.
8. Monitoring and Review
We monitor the effectiveness of our anti-slavery measures through regular reviews of our policies, procedures, and due diligence processes. Key performance indicators include the number of supplier assessments completed, the number of concerns raised and investigated, and the completion rate of employee training.
This statement is reviewed and updated annually to reflect any changes in our business, supply chains, or the legal and regulatory landscape. The review is conducted by Glasshouse's senior leadership team with input from our legal and compliance functions.
We welcome feedback on our approach to combating modern slavery. Any questions or concerns about this statement or our anti-slavery practices may be directed to legal@glasshouse.sh.
9. Approval
This statement has been approved by the board of directors of Glasshouse Ltd and constitutes our modern slavery and human trafficking statement for the financial year ending 31 March 2025.
This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and will be reviewed and updated on an annual basis.
Signed by the directors of Glasshouse Ltd on 15 December 2024.