Modern Slavery Policy

Senso Ventures Limited · Reviewed annually

Senso Ventures Limited is below the £36 million turnover threshold at which section 54 of the Modern Slavery Act 2015 requires an organisation to publish a statement. We publish this one voluntarily, in the form section 54 asks for, because our clients and their procurement teams are entitled to know how a supplier thinks about this, and because a small studio has no excuse for not knowing who it buys from.

This statement sets out the steps we have taken during the financial year ended 31 December 2025 to make sure that slavery, servitude, forced or compulsory labour and human trafficking are not taking place in our business or our supply chain.

1. Who we are and what we do

Senso Ventures Limited (company number 14518265) is a design and technology studio registered in England and Wales, working with clients on brand, digital products and websites. We are a small, senior team. Delivery is carried out by our own people and by a bench of individually engaged specialist freelancers.

We do not manufacture goods, we do not operate warehousing or logistics, and we do not recruit labour through agencies, gangmasters or labour supply intermediaries. Our turnover for the year ended 31 December 2025 was below the section 54 reporting threshold.

2. Our supply chain

Our supply chain is short and, for the most part, low risk. It falls into four groups.

Software and infrastructure. Design, development, hosting, analytics and business tooling bought as subscriptions from established technology providers, most of which publish their own modern slavery statements.

Individual freelancers and specialist partners. Designers, developers, writers, motion artists, photographers and similar, engaged directly by us under written contracts, at agreed rates, on defined payment terms. We contract with the individual or their own limited company, not through a labour intermediary.

Professional services. Accountancy, legal, insurance and banking.

Physical production, where a project calls for it. Print, packaging, signage, merchandise, garments, event build and hardware. This is occasional rather than routine, and it is where the real risk sits, because it reaches manufacturing and raw material supply chains that we do not control and cannot see all the way down.

3. Where we think the risk is

We assess the risk of modern slavery within our own operations as very low. We employ and engage a small number of skilled, senior people in the UK and other established markets, on written terms, paid at professional rates.

The risk in our supply chain is concentrated in physical production. Printed matter, promotional merchandise, branded garments and electronic hardware are categories with documented exposure to forced labour, sub-contracting and unchecked lower tiers of supply, particularly outside the UK and EU. A studio of our size buys these infrequently and in small volumes, which limits exposure but also limits leverage, so we manage it by choosing suppliers carefully rather than by auditing them.

We treat two further areas as worth watching: crowdsourced or platform-brokered creative labour, where the working conditions behind a low price are invisible to the buyer, and any client project that asks us to source production directly in a higher risk market.

4. Our policies

We maintain and apply the following positions.

Zero tolerance. We will not knowingly work with any supplier, partner or client involved in slavery, servitude, forced or compulsory labour, child labour or human trafficking, and we will end a relationship where credible evidence of it emerges.

Fair engagement of freelancers. Everyone we engage works under a written agreement with a defined scope, an agreed rate and clear payment terms. We do not run unpaid internships, we do not ask for unpaid speculative or pitch work, and we do not withhold or delay payment as a means of control. We pay our contractors on the terms we agreed, which are typically 14 days.

No labour intermediaries. We engage individuals and their own companies directly. We do not use labour supply agencies, umbrella arrangements or gangmasters, so the recruitment fee and debt bondage risks that come with them do not arise.

Speaking up. Anyone working with us, in any capacity, can raise a concern about working conditions or human rights directly with a director, in confidence, at [email protected]. We will investigate, we will not retaliate, and we will report credible suspicions of modern slavery to the Modern Slavery Helpline on 08000 121 700 and, where appropriate, to the police.

5. Due diligence

Given our size, our due diligence is proportionate and practical rather than programmatic.

• Before we engage a new freelancer or partner, we deal with the individual or their company directly, agree written terms, and confirm they are working for themselves rather than being supplied by someone else.
• Before we place production work, we ask the supplier for their modern slavery position and, where they are large enough to publish one, we read their statement. We favour UK and EU suppliers, and suppliers who can tell us where the goods are actually made.
• We prefer named, traceable suppliers over marketplaces and unnamed intermediaries, including where that costs more.
• Our contract terms with freelancers and partners require compliance with applicable law, which includes the Modern Slavery Act 2015, and permit us to terminate for breach.
• Where a client asks us to procure production, we source it in the open with them rather than through an undisclosed chain, and we will say so if we do not think a price is achievable without cutting corners on labour.

6. Measuring effectiveness

We do not pretend to run a KPI dashboard for a business of our size. We track a small number of things that would actually tell us if something was wrong:

• the number of concerns raised through the route in section 4 (in the year to 31 December 2025: nil;
• the number of production suppliers engaged in the year, and how many were asked about their labour standards before we placed work;
• whether every freelancer engaged in the year worked under a written agreement with an agreed rate (yes); and
• whether any supplier relationship was ended on human rights grounds (in the year to 31 December 2025: nil].

We review these annually when we prepare this statement.

7. Training and awareness

Modern slavery risk is covered in the induction we give anyone joining the studio, and directors keep up to date with Home Office guidance for suppliers. Because the practical decisions sit with the people who buy production, our focus is on making sure whoever places an order knows what to ask a supplier before they place it, rather than on formal training modules.

8. What we will do next

For the year ending 31 December [2026] we intend to:

• add an explicit modern slavery and labour standards clause to our standard freelancer and supplier terms, rather than relying on a general compliance obligation;
• keep a simple written record of the labour standards checks made on every production supplier before we place work; and
• publish this statement annually within six months of our financial year end, keeping previous versions available so our position can be tracked over time.

This statement is made voluntarily for the financial year ended 31 December [2025]. It has been approved by the board of Senso Ventures Limited.

Benjamin Rutter Director, Senso Ventures Limited 14th January 2026

Senso Ventures Limited · Company number 14518265 · Registered in England and Wales.