1) Purpose & Commitment

Seedling (Beyond Carbon Neutral Ltd) (“Seedling”, “we”, “our”) takes a zero-tolerance approach to modern slavery, human trafficking, forced or compulsory labour, and child labour in any form. We are committed to acting ethically, with integrity and transparency in our own business and in our supply chains. This Policy sets out how we prevent, detect, and respond to modern slavery risks and, if/when we meet the statutory threshold, how we will meet the Modern Slavery Act 2015 section 54 reporting duty.

2) Scope

This Policy applies to all Seedling employees, officers and directors, as well as contractors, temporary workers, interns, and anyone acting on our behalf. It also sets expectations for our suppliers and other third parties who provide goods or services to Seedling.

3) Our Business & Risk Profile

Seedling is a UK-based software company providing digital products and services. Our direct operations are office-based with a low inherent risk profile. Elevated risks may exist in indirect tiers of our supply chain, notably:

• IT hardware & peripherals (manufacturing geographies and raw materials),
• Cloud hosting & data centre services (contracting models and sub-processors),
• Facilities & office services (cleaning, catering, security), and
• Professional services & labour providers (outsourced development/testing, recruiters).

We review these risks annually and whenever we enter new categories or geographies.

4) Legal & Voluntary Commitments

• If our global turnover is £36m or more, and we carry on business in the UK, we will publish an annual Slavery and Human Trafficking Statement approved by the board, signed by a director, and (if we maintain a website) linked from the homepage, covering our financial year. If we take no steps, the statement will say so (though our aim is continuous improvement).
• While we are below the statutory threshold, we adopt the same principles and will publish a voluntary statement or summary where appropriate. (This policy remains in force regardless of threshold.)

5) Responsibilities & Governance
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• Board of Directors: overall accountability; reviews and approves this Policy annually; approves any MSA section 54 statement and ensures it is signed by a director.
• Co-founders / Directors: Policy owners; ensures adequate resources, training, and implementation.
• All Staff: must read, understand and comply; promptly report concerns.6) Policies & StandardsWe apply and maintain:
• This Modern Slavery Policy;
• Supplier Code of Conduct (includes modern slavery, wages, hours, freedom of movement & association, safe conditions, and remediation expectations);
• Whistleblowing/Speak-Up Policy (confidential reporting, non-retaliation);
• Recruitment Policy (lawful right-to-work checks, transparent contracts).

7) Due Diligence in Our Supply Chain

Proportionate to risk and spend, we will:

1. Map suppliers in higher-risk categories/geographies and identify sub-tiers where feasible.
2. Screen new suppliers using questionnaires and/or independent assessments (e.g., labour standards questions, certifications, and audit results).
3. Contractual controls: include anti-slavery clauses, flow-down obligations, audit/verification rights, and termination for breach.
4. Ongoing monitoring: re-assess risk annually or on trigger events (incidents, media reports, significant change in scope or location).
5. Escalation & remediation: if issues are identified, we will work with the supplier on a corrective action plan with time-bound milestones; where remediation fails or abuse is severe, we will suspend or terminate the relationship and report as appropriate to authorities.

(When in scope for section 54, our annual Statement will describe these steps for the relevant financial year.)

8) Risk Assessment & Management

We use a simple, documented methodology that considers: country risk (rule of law, migrant labour, conflict), sector risk (electronics, facilities), product/service risk (labour intensity), and business model risk (outsourcing, subcontracting). We assign risk ratings and prioritise actions accordingly, recording outcomes for transparency in our Statement where required.

9) Training & Awareness

• Mandatory induction for all staff (recognising red flags, reporting channels).
• Targeted training for procurement, HR, and leadership (due diligence, interviewing labour providers, reading third-party audits).
• Annual refreshers and update bulletins when laws/guidance change (e.g., updated Home Office TISC guidance).

10) Speaking Up (Confidential Reporting)

We encourage anyone to raise concerns, including suppliers and contractors. Reports can be made via:

• Email: hello@seedling.earth
• Line manager

We prohibit retaliation against anyone who raises a concern in good faith. We will investigate and, where appropriate, notify law enforcement or other authorities.

11) Measuring Effectiveness (KPIs)

We track and review, at least annually:
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• % of spend covered by risk assessment and due diligence;
• % of high-risk suppliers with contractual anti-slavery clauses and verified controls;
• Number and outcome of concerns raised;
• Time to close corrective action plans.

12) Working with Partners & Remediation

We expect suppliers to maintain effective grievance mechanisms for workers and to provide or cooperate in remediation where harm has occurred (e.g., repayment of recruitment fees, support for affected workers). We will prioritise solutions that protect workers from further harm.

13) Review, Approval & Publication

• This Policy is reviewed annually and after any material change in law or our risk profile.
• If we meet the section 54 threshold, our Modern Slavery Statement will be approved by the board for each financial year, signed by a director, and (if we host a website) published with a prominent homepage link within 6 months of year-end or as otherwise recommended by guidance.