Modern Slavery & Human Trafficking Statement 

1. Introduction

This statement is made by Caraffi Limited pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2025.

Caraffi is a UK-headquartered talent advisory and recruitment process outsourcing (RPO/MSP) business. We are committed to conducting our business ethically and with integrity, and to preventing modern slavery and human trafficking in all aspects of our operations and supply chain. This is our first statement published under the Act.

2. Our Organisation and Business

Caraffi Limited is incorporated and headquartered in the United Kingdom. We are a talent advisory business specialising in the design and delivery of people strategies, including RPO (Recruitment Process Outsourcing) and MSP (Managed Service Provider) solutions. We connect our clients with skilled professionals and provide strategic workforce advice across a range of sectors.

For the financial year ending 31 December 2025, Caraffi had an annual turnover of approximately £40 million and employed approximately 105 people. Our direct employees are principally based in the United Kingdom. Separately, as part of our MSP and RPO services, Caraffi places workers with client organisations. This Statement covers both our workforce and those individuals placed by Caraffi with clients.

3. Our Supply Chains

As a talent advisory and recruitment business, we operate primarily as a direct service provider. Our supply chain is relatively contained and principally comprises the following categories of supplier and partner:

• Technology platforms – including applicant tracking systems, HR technology and candidate attraction tools such as programmatic advertising and job distribution platforms (including international platforms such as Appcast)
• Specialist freelance professionals – including photographers engaged for employer brand projects and occupational psychologists engaged for assessment and selection work
• Professional and business services – including legal, financial and insurance advisers
• Office and facilities suppliers – including IT equipment, consumables and premises-related services
• Recruitment supply chain partners – we engage a small number of third-party recruitment agencies to source candidates where required. These agencies are expected to operate in accordance with our ethical recruitment standards
• Umbrella companies – engaged where Caraffi arranges umbrella company payroll as part of our MSP service delivery. Umbrella companies are expected to operate in accordance with our ethical recruitment standards

Where we engage third-party agencies to introduce candidates, we take additional care to satisfy ourselves that those agencies adhere to applicable labour laws and ethical recruitment practices.

4. Our Policies

Caraffi maintains a Modern Slavery and Human Trafficking Policy that sets out our zero-tolerance approach to slavery and human trafficking in our operations, supply chain and recruitment activities, including in respect of workers placed with clients. The policy is reviewed regularly and applies to all employees, contractors, placed workers and business partners operating on our behalf.

Overall responsibility for ensuring compliance with our Modern Slavery and Human Trafficking Policy rests with the Chief Operating Officer, who is responsible for overseeing the implementation of this policy, reviewing reported concerns and ensuring appropriate action is taken where required.

Our broader policy framework relevant to modern slavery includes:

• Modern Slavery and Human Trafficking Policy – sets out our zero-tolerance commitment, defines relevant terms, allocates responsibilities and establishes reporting obligations. We do not knowingly enter business relationships with any organisation involved in or supportive of slavery, servitude or forced or compulsory labour, including recruitment supply chain partners
• Recruitment and Right to Work Policy – all candidates and placed workers are verified as legally entitled to work in the UK before engagement; our recruitment practices are designed to ensure individuals are treated with dignity, respect and free from coercion
• Whistleblowing Policy – all employees and workers can report concerns confidentially and without fear of reprisal, including concerns relating to modern slavery or human trafficking
• Anti-Bribery and Corruption Policy – underpins our broader commitment to ethical business conduct

5. Due Diligence Processes

We take a proportionate and risk-based approach to due diligence in our supply chain. Our current processes include:

Supplier onboarding

Caraffi is in the process of formalising a supplier due diligence framework to support our modern slavery compliance programme. During 2026, this will include the introduction of a supplier vetting questionnaire for new labour supply chain partners, including recruitment agencies and umbrella companies.

In the meantime, Caraffi applies a proportionate, risk-based approach to supplier due diligence. Depending on the nature of the supplier relationship and the level of risk presented, this may include reviewing publicly available information, verifying corporate legitimacy and insurance documentation, and requesting confirmation of compliance with applicable anti-slavery legislation and labour standards. Where concerns are identified, Caraffi reserves the right not to engage, or to discontinue engagement with, a supplier.

Third-party recruitment agencies and umbrella companies engaged as part of Caraffi’s labour supply chain are subject to enhanced scrutiny, including confirmation of relevant worker verification procedures and compliance with applicable employment and recruitment legislation.

Candidate and worker verification

As a recruitment business, our own processes directly reduce the risk of labour exploitation. We verify the identity and right to work of all individuals we place or engage and adhere to the Conduct of Employment Agencies and Employment Businesses Regulations 2003. We do not charge recruitment fees to candidates or workers, retain original identity documents, restrict an individual's freedom of movement or require deposits or financial guarantees as a condition of employment. These controls form part of our commitment to ethical recruitment practices and the prevention of labour exploitation.

We are currently developing guidance for our recruitment staff on identifying indicators of potential exploitation in candidate interactions and intend to introduce formal modern slavery awareness training for relevant employees during 2026.

Ongoing monitoring

We maintain open communication channels with our supplier base and review key supplier relationships on an ongoing basis. Where concerns arise regarding the conduct of a supplier, partner, or placed worker situation, matters are escalated to the Chief Operating Officer or their nominated representative for modern slavery compliance. Where there are reasonable grounds to suspect that modern slavery or human trafficking is occurring, Caraffi will refer the matter to the relevant authorities. Employees, workers, and individuals placed by Caraffi with clients are encouraged to report concerns through our Whistleblowing Policy and may also contact the Modern Slavery Helpline (0800 0121 700) or the Gangmasters and Labour Abuse Authority (GLAA) directly. We will not penalise anyone for raising a concern in good faith.

6. Risk Assessment

We assess the risk of modern slavery within our operations and supply chain as relatively low, given the nature of our business and the composition of our supply chain. The factors informing this assessment include:

• We operate in a regulated sector and are subject to oversight under employment agency legislation
• Our supply chain is predominantly composed of UK-registered professional services and technology businesses
• We do not operate in high-risk sectors such as agriculture, manufacturing, construction or hospitality, which are identified by the Home Office as carrying elevated modern slavery risk
• Our UK-based employees are employed under standard contracts and subject to UK employment law protections

We recognise that some residual risk exists in the following areas:

• Our use of international candidate attraction platforms, where operations and labour practices are outside our direct control
• Our occasional engagement of freelance specialists, where the employment relationship is less visible than with directly engaged staff
• The placement of workers with clients, where Caraffi has limited visibility of the working environment once individuals are on site
• Our use of third-party recruitment agencies as supply chain partners, where candidate sourcing practices may vary
• Contingent workers placed with clients through our MSP services, where employment relationships and day-to-day working environments may be managed by third parties and are therefore outside Caraffi's direct control. All umbrella company providers engaged by Caraffi are subject to enhanced due diligence and vetting as part of our supplier due diligence process

We mitigate these risks through our supplier onboarding and vetting processes, our right to work and candidate verification procedures, our selection of established and reputable partners, and our whistleblowing and reporting channels. We keep our risk assessment under review and will update it annually as part of our Statement review process.

7. Training and Awareness for 2026

We are committed to ensuring that our people are equipped to identify and respond to the risks of modern slavery. As this is our first statutory Statement, we are establishing our baseline position with regard to training and awareness.

Our current approach includes:

• All employees are made aware of our Modern Slavery and Human Trafficking Policy upon joining Caraffi
• Our whistleblowing channels are communicated to all staff and are available to employees and contingent workers

We recognise that our training provision requires further development. During 2026 we intend to:

• Introduce formal modern slavery awareness training for all employees
• Develop specific guidance for recruitment staff and managers on identifying red flags and applying due diligence in candidate interactions and supplier management
• Review and update relevant supplier and contingent worker documentation to include appropriate modern slavery and whistleblowing provisions

We will report on progress against these commitments in our Statement for the financial year ending 31 December 2026.

8. Key Performance Indicators and Governance Measures

As this is our first statement under the Modern Slavery Act 2015, we are establishing our baseline position. We intend to measure our progress in future years against the following indicators:

• Percentage of labour supply chain partners subject to due diligence review at onboarding
• Completion rate of modern slavery awareness training by all employees
• Completion rate of red flag and due diligence guidance by recruitment staff and managers
• Number of modern slavery-related concerns raised through our whistleblowing channel
• Annual review of this Statement with board sign-off

We will report on progress against these indicators in our Statement for the financial year ending 31 December 2026.

9. Board Approval

This statement has been reviewed and approved by the Board of Directors of Caraffi Limited and is signed on our behalf by:

Graeme Paxton

Chief Executive Officer, Caraffi Limited

Date: 9th July 2026

This Statement will be reviewed and updated annually. Our next Statement, covering the financial year ending 31 December 2026, will report on progress against the indicators and commitments set out above.