Human Rights & Modern Day Slavery Policy

Effective Date: 01/03/2026

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At Caspian One, we are committed to upholding high standards of ethical conduct and respect for human rights across all aspects of our business operations. Our commitment to equity, diversity, and inclusion (EDI) underpins our approach, ensuring that every individual - whether employee, contractor, client, or stakeholder - operates in an environment grounded in respect, fairness, and dignity.

As a professional services provider operating within regulated financial services, we recognise the responsibility we bear in identifying, preventing, and mitigating the risks of modern slavery and human trafficking within our sphere of influence. Through leadership, proportionate governance, and transparency, we aim to foster a culture of accountability that reflects the values we uphold.

Caspian One is committed to preventing modern slavery and human trafficking in our business and supply chains. By aligning our policies and practices with our EDI principles, we seek to contribute to a working environment in which individuals are treated lawfully, ethically, and with respect.

This statement has been published pursuant to Section 54 of the UK Modern Slavery Act 2015 and outlines the steps taken by Caspian One Limited during the relevant financial year to prevent modern slavery and human trafficking. This statement covers the following entities across our group:-

  • Caspian One Limited

  • Caspian One Open Data Limited

  • Responsibility for oversight of this statement and related policies sits with senior leadership. We have a zero-tolerance approach to modern slavery and human trafficking within our business and supply chains.

    Our approach to preventing modern slavery is supported by internal policies and procedures, including:

    • Modern Slavery and Human Rights Policy

    • Whistleblowing Policy

    • Anti-Bribery and Corruption Policy

    • Recruitment and onboarding controls

    • Supplier engagement and due diligence procedures

    These policies are reviewed periodically to ensure they remain proportionate and appropriate to the size and nature of our business.

  • As a global professional services provider, we deliver specialist technology capability and project-led services to regulated financial institutions across the UK, Europe, and North America.

    Given the nature of our services, we assess our direct exposure to modern slavery risk as lower than organisations operating in manufacturing, logistics, or high-risk labour sectors. However, we recognise that risk can arise indirectly through supply chains and third-party relationships.

    We assess potential modern slavery risks across:

    • Supply chain relationships

    • Third-party service providers

    • Cross-border engagements

    Risk assessments are conducted proportionately, taking into account:

    • Geographic exposure

    • Nature of services provided

    • Type and structure of supplier relationships

  • We undertake proportionate due diligence when engaging suppliers and partners. This may include:

    • Reviewing supplier policies and governance frameworks

    • Including contractual provisions requiring compliance with applicable anti-slavery and human rights legislation

    • Assessing risk indicators where appropriate

    We expect all suppliers and partners to uphold standards consistent with applicable human rights and anti-slavery laws. We also expect all suppliers to uphold similar standards throughout their supply chain including being engaged under written contracts, requiring all relevant laws and ethics to be upheld.

  • We provide awareness and guidance to relevant personnel to support understanding of:

    • Modern slavery risks

    • Ethical conduct expectations

    • Reporting mechanisms

    Training is proportionate to role and risk exposure and supports a culture of accountability and psychological safety.

  • Caspian One encourages employees, contractors, and stakeholders to raise concerns regarding suspected wrongdoing, including modern slavery and human trafficking. Concerns may relate to:

    • Forced labour or exploitation

    • Human trafficking

    • Bribery or corruption

    • Fraud or other criminal conduct

    We prohibit retaliation against individuals who raise genuine concerns in good faith. Reports are handled confidentially and in accordance with internal procedures. Our Whistleblowing Policy is available here.

  • We recognise that preventing modern slavery requires ongoing vigilance. We therefore:

    • Periodically review our policies, procedures and training

    • Monitor legal and regulatory developments

    • Refine controls where appropriate

    Our approach is informed by legal requirements, operational experience, and our commitment to ethical and inclusive business practices.

  • Contact

    For questions regarding this statement or our approach to human rights and modern slavery, please

    contact: Email: hello@caspianone.com

    Approval

    This statement has been approved by the Board of Caspian One Limited on 4th March 2026 and is reviewed annually.