Modern Slavery Statement

Introduction and Our Commitment

The Data Observatory CIC is a Community Interest Company and the United Kingdom's dedicated think tank for data and analytics in health and social care. Our purpose is to help the health and social care system make the best use of data for social good. That purpose places human dignity at the centre of everything we do, and modern slavery is one of the gravest violations of human dignity there is.

We are not legally required to publish a statement under Section 54 of the Modern Slavery Act 2015, because our annual turnover is below the £36 million threshold that brings an organisation within scope of that provision. We publish this statement voluntarily. We do so because the Home Office guidance encourages organisations of every size to be transparent about their work, and because we believe an organisation founded on the principle of using data for social good should hold itself to a higher standard than the law strictly demands.

This statement is made in line with the spirit of Section 54 of the Modern Slavery Act 2015 and reflects the structure set out in Section 54(5) of the Act and the Home Office statutory guidance, Transparency in Supply Chains: a practical guide, updated 1 December 2025. It sets out the steps the Data Observatory took during the financial year ending 31 March 2026, and the steps we continue to take, to understand and address the risk of modern slavery and human trafficking in our own activities and across our supply chain.

We recognise the reality set out in the Government's guidance, that no sector and no part of the world is free from the risk of modern slavery, and that an organisation reporting no risk at all has most likely not looked hard enough. We have approached this statement in that honest spirit. Rather than claim our risk is nil, we have set out where our genuine exposure lies, modest though it is, and what we do to manage it.

As a Community Interest Company, we are bound by a statutory asset lock and are accountable to the Office of the Regulator of Community Interest Companies for serving our community purpose. We are constituted, in other words, around social good rather than private profit. We regard the prevention of modern slavery not as a compliance obligation bolted on to our business, but as a direct expression of the values on which the Data Observatory was founded.

1. Our Structure, Our Business and Our Supply Chains

The Data Observatory CIC is a Community Interest Company limited by shares, registered in England and Wales and established under the Schedule 2 structure. We operate as an independent, not-for-profit think tank. The Schedule 2 structure, together with the statutory asset lock, means that our assets and profits are dedicated to our community purpose rather than extracted as dividends, so that in substance we operate as a pure community-benefit organisation. We are accountable to the Office of the Regulator of Community Interest Companies for delivering against our community interest objectives.

We are a small organisation. We do not employ staff on payroll. Our work is delivered by a network of experienced associates and specialist consultants who are engaged on a contract basis, alongside partnership working with the NHS Chief Data and Analytical Officers Network (CDAON) and other system partners. This model lets us bring together senior data and analytics leaders with deep, real-world health and care experience for specific pieces of work, rather than maintaining a permanent workforce.

Our business is the provision of professional and intellectual services: thought leadership, applied analytics, advisory and consultancy work, fellowships, research, and convening activities, delivered to and with the NHS, local government, academia and other organisations across the health and social care sector. We do not manufacture, import, distribute or sell physical goods, and we do not operate in the high-risk sectors, such as agriculture, construction, manufacturing, garments or extraction, where labour exploitation is most commonly found.

Our supply chain is correspondingly narrow and consists of two main elements. The first is our delivery supply chain: the associates, independent consultants and specialist professional service providers we contract with to deliver our work. These are predominantly senior professionals based in the United Kingdom, engaged either as individuals or, in many cases, through their own limited companies or as sole traders. Where we contract a limited company, the work may be carried out by that company's own people rather than by a single named individual. We do not engage anyone through staffing agencies, umbrella companies or other labour-supply intermediaries. The second element is our operational supply chain: the goods and services we buy to run a small office-light organisation, which includes digital tools and software subscriptions, cloud and data hosting, professional services such as accountancy and legal advice, and occasional travel, venue hire and catering for roundtables and events.

We are honest about the limits of our current knowledge. Our direct contractual relationships, our tier one suppliers, are well understood because there are few of them and we deal with them directly. We have less visibility of the supply chains that sit behind our suppliers, for example the labour conditions in the data centres that underpin the cloud services we use, or the suppliers used by the venues and caterers we engage. Improving our understanding of these lower tiers is one of the areas we intend to develop, and we set this out in the section on continuous improvement below.

2. Our Policies in Relation to Slavery and Human Trafficking

The Data Observatory has a zero-tolerance approach to modern slavery and human trafficking. We will not knowingly work with any individual or organisation involved in or facilitating modern slavery in any form, whether in our own activities or in our supply chain.

This commitment is given practical effect through the following policies and principles:

• This statement sets out our public commitment and is reviewed and approved annually.
• Ethical contracting. Our standard terms with associates, consultants and suppliers require compliance with all applicable laws, including the Modern Slavery Act 2015 and employment, right-to-work and health and safety law.
• Lawful and fair engagement of people. Although we do not run a payroll, we are committed to fair, transparent and lawful terms with every person who delivers work for us. We verify the right to work where this applies, we pay fairly and promptly, and we do not use unpaid or coerced labour of any kind.
• Whistleblowing and raising concerns. Anyone working for or with the Data Observatory can raise a concern about modern slavery, or any other unethical practice, without fear of disadvantage. Concerns can be raised directly with the Board.
• Procurement and supplier selection. We factor ethical conduct, including the management of modern slavery risk, into our choice of significant suppliers, particularly where we engage suppliers in higher-risk categories such as events, hospitality and travel.
• Expectations of those we work with. We expect all suppliers, consultants and associates working on behalf of the Data Observatory CIC to comply with the Modern Slavery Act 2015 and to maintain policies and procedures proportionate to their own size and risk profile.

Because we are a small organisation, several of these policies are necessarily proportionate rather than elaborate. We would rather hold a small number of clear, genuinely applied commitments than a large policy library that does not reflect how we actually work.

3. Due Diligence Processes

Our due diligence is proportionate to our size and to the relatively low inherent risk of our service-based, professionally staffed model. In practice it means:

• Knowing who we work with. Because we engage a small number of senior associates, consultants and specialist firms directly, we know the people and organisations delivering our work. This direct relationship is itself a strong safeguard against the kinds of hidden, intermediated labour exploitation that arise in large, anonymous workforces. We do not use staffing agencies, umbrella companies or other labour-supply intermediaries.
• Checking the credentials of the firms we commission. When we commission a limited company or other organisation to deliver work for us, we review their relevant policies as part of deciding who we work with, including their modern slavery statement or policy where they have one.
• Right-to-work and identity checks where the nature of an engagement makes them legally appropriate. We recognise that statutory right-to-work checks apply principally to employees and certain workers rather than to genuine business-to-business contracts with limited companies, and we apply them accordingly rather than as a blanket formality.
• Contractual safeguards requiring our associates, consultants and suppliers to comply with the Modern Slavery Act 2015 and related law.
• Proportionate supplier consideration. When we engage suppliers in higher-risk categories, principally event venues, catering and travel, we give weight to suppliers that can demonstrate their own ethical and modern slavery commitments.
• Remediation. If we identified that modern slavery had occurred in our activities or supply chain, our priority would be the safety and wellbeing of the affected individual. We would take a victim-centred approach, seek specialist advice from relevant organisations before acting, report to the appropriate authorities, and review the relationship that gave rise to the harm. We would not take knee-jerk action, such as immediately terminating a supplier, where doing so could leave a victim in a worse position.

4. Risk: Where It May Arise and How We Manage It

We have assessed where modern slavery risk is most likely to arise for an organisation like ours. Our overall inherent risk is low, for three main reasons: we provide professional services rather than physical goods, the people delivering our work are predominantly senior UK-based professionals engaged directly, and we do not operate in the sectors or geographies most associated with labour exploitation.

That said, we do not claim our risk is zero. The areas of greatest relative risk are:

• Our wider operational supply chain, below tier one. The digital, cloud and hardware services we rely on ultimately depend on global supply chains, including electronics manufacturing and data centre operations, where modern slavery risk is well documented. Our leverage over these large suppliers is limited, but it is where our most material residual risk sits.
• Events, hospitality and travel. Where we hold in-person roundtables and events, the catering, venue and cleaning services involved draw on sectors with a recognised history of labour exploitation.
• The people behind the firms we commission. Where we contract a limited company or other organisation, the work may be delivered by that company's own staff or associates, whom we do not engage directly. The risk here is low, because these are established UK professional firms, but it is not literally nil. We manage it by reviewing the policies of the firms we commission before deciding to work with them.

We manage these risks proportionately: by keeping our delivery supply chain short and direct, by reviewing the policies of the firms we commission, by favouring suppliers with credible ethical credentials in the higher-risk categories, and by remaining alert as our activities grow. We do not use staffing agencies, umbrella companies or other labour-supply intermediaries, and we are conscious that moving to agency-supplied labour, or significantly scaling up our events, would change our risk profile. We would strengthen our due diligence accordingly before doing so.

5. Training and Capacity Building

Given our size and the absence of a payroll workforce, we do not run a formal staff training programme. Instead, our approach to capacity building is twofold.

Internally, the members of our Board and our core associates are familiar with the requirements of the Modern Slavery Act 2015 and the indicators of modern slavery, and understand how to escalate a concern. We will continue to ensure that anyone taking on responsibility for procurement or for engaging suppliers and associates is briefed on modern slavery risk.

Externally, our work itself contributes to the wider system. As a think tank dedicated to data and analytics in health and social care, we help the NHS, local government and others build analytical capability and create data-driven solutions, the means by which vulnerability and hidden harm are identified.

6. Monitoring Our Effectiveness

As a small organisation publishing voluntarily, we measure our effectiveness in proportionate but honest terms. For the period covered by this statement, our indicators are:

• Whether we have reviewed and published this statement, with Board approval, on an annual basis
• The proportion of our significant suppliers and contracted associates whose terms include modern slavery and related legal compliance
• The number of modern slavery concerns raised and, where any are raised, how they were handled
• Whether, in higher-risk procurement categories such as events and travel, we gave preference to suppliers able to demonstrate their own ethical commitments

We recognise that the absence of any reported concern is not, on its own, evidence of effectiveness. We treat it instead as a prompt to keep asking whether we are looking hard enough.

Day-to-day responsibility for monitoring compliance with this statement sits with the Chief Executive Officer, with overall accountability resting with the Board of Directors of the Data Observatory CIC.

Actions Taken During the Financial Year Ending 31 March 2026

During the year covered by this statement, we took the following steps:

• Reviewed our active suppliers, associates and consultants to confirm how each is engaged
• Confirmed that all contracted associates and consultants were engaged directly, under professional contracts, and that no staffing agencies, umbrella companies or other labour providers were used
• Reviewed the modern slavery commitments of significant suppliers and commissioned firms where these were available, as part of deciding who we work with
• Included modern slavery and legal compliance expectations within our consultancy and supplier arrangements
• Reviewed and approved this statement at Board level

Our Wider Contribution as a Community Interest Company

As a Community Interest Company, we exist to deliver benefit back to society. We are a Community Interest Company limited by shares, established under the Schedule 2 structure, which means that in practice our assets and profits are locked to our community purpose and are not extracted as dividends. We operate, in substance, as a pure community-benefit organisation. What we generate is directed towards our community purpose: improving health and social care through the power of data and analytics. This is a structural commitment, regulated by the Office of the Regulator of Community Interest Companies, and not a discretionary or marketing one.

That purpose takes several forms. We invest directly in people, including through fellowships and bursaries that develop the data and analytics talent the health and social care system depends on. We champion the value of analytical capability at a time when it is under pressure. And we work with the system to create data-driven solutions that help improve outcomes for patients, service users and communities.

The connection to modern slavery is real rather than rhetorical. Modern slavery is, at its core, a problem of people who are hidden, vulnerable and unable to ask for help. Victims frequently surface, often unrecognised, in the very settings we work to support: in primary care, in emergency departments, in social care and in safeguarding systems. While we are not ourselves a safeguarding organisation, the analytical capability we help build, and the data-driven solutions we help create, are precisely what allow public services to identify unmet need, surface hidden harm, target support and protect those most at risk.

We therefore regard our work not as adjacent to the fight against modern slavery, but as one expression of the same purpose: using data to improve and protect lives. Our commitment in this statement sits within that broader social mission, and we hold ourselves to the standard it implies.

Continuous Improvement

Consistent with the Home Office guidance, we view this work as a journey rather than a fixed destination. Looking ahead, we intend to:

• Improve our understanding of the lower tiers of our operational supply chain, particularly our digital and cloud providers
• Continue to favour suppliers with published modern slavery commitments in our higher-risk categories
• Keep our due diligence proportionate to our scale, strengthening it ahead of any growth in our use of events, intermediaries or subcontracted labour
• Consider voluntarily uploading future statements to the Government's modern slavery statement registry as our reporting matures

We will report on progress against these intentions in our next statement.

Objectives for 2026/27

To make our commitment measurable, we have set the following objectives for the year ahead:

• Review modern slavery considerations within all significant supplier and consultant engagements
• Maintain modern slavery and legal compliance expectations in all new consultancy and supplier arrangements
• Review and re-approve this statement annually through the Board