Modern Slavery Statement

1. About this statement

TELT (TransformELT Ltd) has a zero-tolerance approach to modern slavery and human trafficking in all its forms. We are committed to acting ethically and with integrity in all our operations, ensuring that slavery and human trafficking do not exist within our organisation or our supply chains.

TransformELT Ltd's annual turnover is below the £36 million threshold that would require us to publish this statement under Section 54 of the Modern Slavery Act 2015. We choose to publish voluntarily because our clients in the public and international development sectors expect engagement with this issue from all suppliers, and because transparency about our practices is important to us.

This statement covers the financial year ending 30 June 2026. It complements our Safeguarding Policy, Equal Opportunities and Diversity Policy and Code of Conduct.

2. Our organisation and supply chains

TELT is a UK-based education consultancy that specialises in English language teaching, teacher education, curriculum development and research. We operate globally, partnering with public and private institutions, international donors and ministries of education to deliver programmes that promote quality, inclusion and professional development.

We have three staff and engage a network of associate consultants for programme delivery. Our supply chains are primarily comprised of:

• contracted associate consultants, specialist educators and researchers
• local delivery partners and institutional counterparts
• standard business service providers (IT, accounting, insurance)
• travel and accommodation providers for international programme delivery

These are located across the UK and internationally.

3. Risk assessment

As a knowledge-based consultancy, our inherent modern slavery risk is low. We do not manufacture goods, operate in high-risk industries, employ large numbers of low-skilled or migrant workers, or have complex multi-tier supply chains.

We recognise that our greatest risks lie in subcontracted operations outside the UK, particularly in contexts where labour protections are weak or where third-party delivery involves vulnerable populations. Our residual risk areas are:

• Associate consultants in international contexts — fair treatment, timely payment and voluntary engagement must be assured, particularly where consultants are sourced through intermediaries or partner organisations in-country
• Travel and accommodation in developing countries — the hospitality sector is identified internationally as carrying modern slavery risk, particularly in countries with weaker labour protections
• In-country service providers — local transport, venue hire and catering when delivering programmes internationally

In alignment with FCDO programme management guidelines, we conduct context-specific risk assessments before initiating delivery in each operating environment.

4. Due diligence

We conduct due diligence on all new suppliers, consultants and delivery partners. This includes:

• requiring declarations of compliance with anti-slavery laws
• verifying legal status, working conditions and transparency of recruitment practices
• including anti-slavery clauses in consultant and partner contracts
• conducting background checks and requesting references where appropriate
• ensuring engagement terms are clear, payment is prompt and working conditions are reasonable

We prioritise working with local partners who uphold fair labour standards and require all sub-contractors to sign our Code of Conduct, including clauses on labour rights. We maintain regular oversight and reporting mechanisms throughout delivery.

We review these procedures regularly to ensure continued compliance and effectiveness.

5. Measuring effectiveness

To ensure that slavery and human trafficking are not taking place in our operations or supply chains, we maintain the following practices:

• all new contractors and suppliers are subject to due diligence screening
• all staff and associate consultants are made aware of safeguarding and ethical conduct standards
• clear and accessible reporting channels for ethical concerns are in place, of which all staff, associate consultants and sub-contractors are aware
• policies and risk management strategies are reviewed on a regular basis

6. Training

TELT provides training and guidance for staff and associate consultants on safeguarding, ethical conduct and recognising signs of exploitation. This is included in onboarding and before engagement on programmes in higher-risk operating contexts.

All staff and contractors are provided with the Modern Day Slavery Awareness Booklet published by the Home Office, and we reference guidance from organisations including the Ethical Trading Initiative.

7. Reporting concerns

If you have concerns about modern slavery or human trafficking in connection with TELT's work or supply chains, you can report them through the following channels:

• TELT: [governance@teltglobal.com]
• Modern Slavery Helpline: 08000 121 700
• Police: 101 (non-emergency) or 999 (emergency)

TELT is committed to ensuring that anyone who raises a concern in good faith will not be subjected to any form of retaliation or disadvantage.

8. Related policies

This statement should be read alongside:

• TELT's Safeguarding Policy, which addresses related risks in our international programme delivery
• TELT's Equal Opportunities and Diversity Policy

9. Approval and review

This statement is reviewed annually and updated as required to reflect changes in our operations, supply chains or sector expectations.

This statement was approved by Sarah Mount, Director of TransformELT Ltd, on 19 April 2026.