Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Turing Elite Research Labs Limited ("Turing Elite", "we", "our", or "the Company") has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.

Turing Elite Research Labs Limited is a United Kingdom-registered company operating in the field of artificial intelligence research, development, and deployment. We are committed to conducting business ethically and with integrity, and we recognise our responsibility to take a robust approach to slavery and human trafficking in all its forms.

This statement covers the financial year ending 2025 and has been approved by the Board of Directors of Turing Elite Research Labs Limited.

Our Organisation and Structure

Turing Elite Research Labs Limited is a UK-based artificial intelligence research laboratory specialising in sovereign, edge-deployed AI systems. Our principal activities include the research, development, and licensing of foundation models across Vision AI, World Models, Computer Vision, Generative Video, and Generative Audio.

We operate from the United Kingdom and work with partners across multiple sectors including creative industries, defence and security, public safety, healthcare, education, enterprise, and financial services. Our workforce comprises researchers, engineers, and business professionals, the majority of whom are based in the UK.

Our supply chain primarily consists of technology infrastructure providers, cloud computing services, hardware suppliers, professional services firms, academic research institutions, and specialist consultants. We do not operate in industries traditionally associated with high risks of modern slavery, but we remain vigilant across all areas of our business and procurement.

Our Policies in Relation to Slavery and Human Trafficking

Turing Elite is committed to ensuring that there is no modern slavery or human trafficking in any part of our business. The following policies and procedures are relevant to this commitment:

Anti-Slavery and Human Trafficking Policy — We maintain a dedicated policy that sets out our zero-tolerance approach to modern slavery in all its forms. This policy applies to all persons working for us or on our behalf in any capacity, including employees, directors, officers, contractors, consultants, and agency workers.

Recruitment and Employment Practices — We operate robust recruitment procedures that include verification of identity, right-to-work checks in accordance with UK immigration law, and fair employment terms. All employees receive written contracts of employment that clearly set out terms, conditions, and remuneration. We pay all employees at or above the National Living Wage and ensure compliance with Working Time Regulations.

Whistleblowing Policy — We encourage all workers, including agency staff and contractors, to report concerns about any aspect of our business, including any suspicion of modern slavery. We are committed to ensuring that no person suffers detrimental treatment as a result of reporting in good faith their suspicion that modern slavery is or may be taking place.

Code of Conduct — Our Code of Conduct establishes the standards of behaviour expected of all personnel and makes clear that ethical conduct, respect for human rights, and compliance with applicable laws are non-negotiable requirements of working with Turing Elite.

Due Diligence Processes

We undertake due diligence when considering new suppliers and regularly review our existing supply chains. Our due diligence processes include:

Supplier Assessment — We evaluate new suppliers against criteria that include their own policies and practices in relation to modern slavery. Where appropriate, we require suppliers to confirm their compliance with the Modern Slavery Act 2015 and to demonstrate that they have adequate procedures in place to identify and address risks of modern slavery in their own operations and supply chains.

Contractual Provisions — Our supplier agreements include provisions requiring compliance with all applicable laws, including those relating to modern slavery and human trafficking. We reserve the right to terminate relationships with suppliers who fail to meet these standards.

Ongoing Monitoring — We monitor our supply chain on an ongoing basis and take steps to investigate any concerns that are raised. Where we identify risks, we work with the relevant supplier to address them and, where necessary, take remedial action including the termination of the business relationship.

Risk Assessment

We recognise that modern slavery is a complex and evolving issue. We have assessed the principal risks of modern slavery within our business and supply chain and consider the following areas to warrant particular attention:

Technology Supply Chain — The global technology supply chain, including the manufacture of hardware components such as GPUs, servers, and networking equipment, can involve complex, multi-tier supply chains with operations in jurisdictions where labour protections may be less robust. We mitigate this risk by procuring hardware from established, reputable suppliers who maintain their own modern slavery policies and supply chain due diligence programmes.

Professional Services and Contractors — We engage specialist consultants and contractors, including in AI research, data annotation, and software development. We mitigate risks in this area through direct engagement practices, verification of identity and right-to-work documentation, and fair contractual terms.

Facilities and Office Services — Building management, cleaning, catering, and security services can present modern slavery risks, particularly where subcontracting is involved. We take steps to ensure that our facilities providers maintain appropriate employment practices and comply with applicable legislation.

Training and Awareness

We are committed to raising awareness of modern slavery issues among our workforce. Key personnel involved in recruitment, procurement, and supply chain management receive guidance on the indicators of modern slavery and the steps to take if they suspect that modern slavery is occurring. We promote a culture of vigilance and responsibility throughout our organisation.

Key Performance Indicators

We measure the effectiveness of our approach to combating modern slavery through the following indicators:

The percentage of new suppliers who have been assessed against our modern slavery criteria. The number of concerns raised by staff or other stakeholders in relation to modern slavery, and the outcome of any investigations. Completion rates for modern slavery awareness activities among relevant personnel. The number of supply chain audits or reviews conducted during the reporting period.

During the reporting period covered by this statement, no instances of modern slavery or human trafficking were identified within our business or supply chains, and no concerns were raised through our whistleblowing procedures in relation to modern slavery.

Our Commitment to Continuous Improvement

We are committed to continuously improving our practices to combat modern slavery and human trafficking. In the coming year, we intend to:

Continue to review and strengthen our supply chain due diligence processes as our business grows and our supply chain develops. Enhance training and awareness programmes for all staff, with particular focus on those in procurement and supplier management roles. Monitor developments in legislation and best practice guidance to ensure our approach remains current and effective. Engage with industry peers and relevant organisations to share best practice and contribute to wider efforts to eradicate modern slavery.

Board Approval

This statement has been approved by the Board of Directors of Turing Elite Research Labs Limited and is signed on behalf of the Board.

Graeme Scott
Director
Turing Elite Research Labs Limited

Date of approval: February 2025
Date of next review: February 2026

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Turing Elite Research Labs Limited's slavery and human trafficking statement for the financial year ending 2025.