Modern Slavery Statement 2026

1) Organisation

This statement applies to Cwiri Ltd ("Cwiri") and covers the company financial year 1 September 2025 to 31 August 2026.

Cwiri is a UK registered company providing environmental monitoring, data analysis, and related research and consultancy services, primarily in relation to natural capital, peatland and woodland projects. The business focuses on the design, deployment and operation of environmental sensing systems and associated data services for public sector bodies, land managers, and research partners.

The company operates from a single registered office in Edinburgh, Scotland. All staff are based in the United Kingdom. Cwiri is not part of a wider corporate group and is overseen by its directors.

The labour supplied to Cwiri in the course of its operations is carried out entirely within the United Kingdom.

2) Definitions

Cwiri considers that modern slavery encompasses:

• human trafficking
• forced labour, including work undertaken under threat or coercion
• being owned, controlled, or exploited by an employer
• being treated as a commodity or being bought or sold as property
• restrictions on freedom of movement

3) Commitment

Cwiri acknowledges its responsibility to help prevent modern slavery and human trafficking and is committed to acting ethically and with integrity in all its business relationships.

The company does not knowingly enter into business with any organisation, in the United Kingdom or elsewhere, that supports, permits, or is found to be involved in slavery, servitude, or forced or compulsory labour.

No labour provided to Cwiri in the provision of its own services is obtained by means of slavery or human trafficking. The company complies with applicable UK employment legislation and associated standards.

4) Supply chains

Cwiri's supply chains are limited in scale and complexity. They primarily relate to:

• specialist environmental monitoring equipment
• IT and telecommunications services
• software, hosting and cloud infrastructure
• professional services such as insurance, accounting and legal advice

The majority of suppliers are UK based or are established providers operating within well regulated markets. Cwiri Ltd does not operate manufacturing facilities and does not rely on labour intensive overseas production.

5) Potential exposure

Cwiri considers its overall exposure to the risk of modern slavery and human trafficking to be low, given:

• the nature of its professional and technical services
• its small workforce, entirely UK based
• relatively short and transparent supply chains

Where risks may arise, they are most likely to be indirect, for example within lower tier supply chains associated with equipment manufacturing or global technology services. These risks are considered limited and proportionate to the scale of the business.

6) Steps taken

Cwiri takes proportionate steps to reduce the risk of modern slavery within its business and supply chains, including:

• using reputable suppliers and service providers
• undertaking basic due diligence when appointing new suppliers
• avoiding suppliers operating in high risk jurisdictions where possible
• reserving the right to terminate relationships where serious ethical concerns arise
• ensuring fair recruitment and employment practices within its own operations

To the company's knowledge, Cwiri has not conducted business with any organisation found to have been involved in modern slavery.

7) Key performance indicators

Given the company's size and low risk profile, Cwiri does not currently operate formal quantitative KPIs specific to modern slavery. Effectiveness is monitored through:

• periodic review of supplier relationships
• awareness of relevant legal and regulatory guidance
• directors' oversight of ethical and responsible business practices

8) Policies

Cwiri's commitment to responsible and ethical operation is supported by related policies and practices, including:

• fair recruitment and employment practices
• compliance with UK employment law
• data protection and information security policies

9) Training

All staff are expected to act in accordance with the company's ethical standards. Awareness of modern slavery risks is addressed through induction and ongoing informal guidance appropriate to the size and nature of the organisation.

The responsibility for oversight of modern slavery issues sits with the company's directors.

10) Approval

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and will be reviewed annually.