Modern Slavery Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Orion Data Analytics Ltd has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.

Although we are not currently required by the Act to publish a modern slavery statement (the mandatory reporting threshold applies to organisations with an annual turnover of £36 million or more), we choose to do so voluntarily as a demonstration of our commitment to ethical business practices, transparency and responsible corporate governance.

This statement covers the financial year ending March 2026 and is approved by the Board of Directors of Orion Data Analytics Ltd.

Orion Data Analytics Ltd is a boutique data analytics and artificial intelligence consultancy registered in England and Wales (company number 15464691). We specialise in Microsoft Azure, Microsoft Fabric, Power Platform and AI strategy, delivering consulting services, software products and assessment tools to organisations across the United Kingdom and internationally.

Our registered office is at The Long Barn, Cobham Park Road, Cobham, Surrey, KT11 3NE, United Kingdom.

Orion Data Analytics Ltd has a zero-tolerance approach to modern slavery, human trafficking, forced labour, child labour and any other form of exploitation. We are committed to:

• Acting ethically and with integrity in all our business relationships.
• Implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place in our business or supply chains.
• Ensuring transparency within our organisation and with our suppliers and partners.
• Respecting the human rights and dignity of all individuals with whom we interact in the course of our business.

As a professional services and technology consultancy, our supply chains primarily consist of:

• Technology providers: Microsoft Corporation (Azure, Microsoft 365, Fabric, Power Platform), Cloudflare, and other enterprise software vendors who maintain their own comprehensive modern slavery and human rights policies.
• Professional services: Subcontracted consultants, freelance specialists and technology partners engaged to support client delivery.
• Corporate services: Office services, telecommunications, accounting, legal and administrative service providers.

We recognise that while our supply chain is predominantly technology and professional services based (which presents a lower inherent risk of modern slavery compared to manufacturing or agriculture), we nevertheless maintain vigilance and conduct appropriate due diligence on our suppliers and partners.

We maintain and enforce the following policies and practices that are relevant to our commitment to preventing modern slavery:

• Ethical conduct: We expect all individuals working with us or on our behalf, in any capacity, to conduct themselves with honesty, integrity and fairness. We do not tolerate any form of exploitation.
• Supplier due diligence: We assess the modern slavery and human trafficking risks of new suppliers and partners as part of our onboarding process.
• Fair employment practices: We comply with all applicable employment legislation, pay at least the National Living Wage, and ensure that all employment relationships are entered into voluntarily and with full transparency regarding terms and conditions.
• Whistleblowing: We encourage all individuals working with us to report any concerns relating to modern slavery, human trafficking or any other form of exploitation without fear of retaliation.

We carry out due diligence on our supply chains by:

• Evaluating potential suppliers and partners for their approach to modern slavery and ethical practices before entering into business relationships.
• Requiring our key technology partners and subcontractors to confirm their compliance with the Modern Slavery Act 2015, where applicable, or to demonstrate equivalent ethical standards.
• Reviewing the modern slavery statements and corporate responsibility policies of our principal suppliers, including Microsoft Corporation.
• Reserving the right to terminate any business relationship where there is evidence or reasonable suspicion of modern slavery or human trafficking.

We have assessed the risk of modern slavery occurring within our business and supply chains. Given the nature of our operations as a UK-based professional services and technology consultancy, our overall risk is assessed as low. The key factors supporting this assessment are:

• Our workforce comprises skilled professionals in the United Kingdom, all employed under transparent contracts with clearly defined terms and conditions.
• Our supply chain is predominantly composed of established, regulated technology companies and professional services firms with their own robust anti-slavery policies.
• We do not operate in or source from jurisdictions identified as high-risk for modern slavery by the Global Slavery Index.
• We do not use recruitment agencies that operate in high-risk sectors or jurisdictions.

We will continue to monitor and reassess these risks as our business grows, enters new markets or engages new suppliers.

We ensure that all directors and team members are made aware of the risks of modern slavery and human trafficking, and understand the indicators to look for. As we grow, we will implement formal training programmes to ensure continued awareness and compliance across our organisation.

We encourage anyone who has concerns about modern slavery, human trafficking or exploitation within our business or supply chains to report those concerns immediately. Reports can be made to:

• Email: enquiries@oriondata.co.uk
• Telephone: +44 (0)7795 467 284

All reports will be investigated promptly and treated in confidence. We will not tolerate any retaliation against individuals who raise genuine concerns in good faith.

You may also report suspected modern slavery to the Modern Slavery Helpline at 08000 121 700 or via www.modernslaveryhelpline.org.