Organization structure and supply chains
Bramble is a small owner-managed group of companies: Bramble Hub Limited and Bramble People Limited (no longer trading); and their holding company: Bramble Effect Limited.
Bramble Hub specializes in UK public sector framework contracts for IT and related professional services consultancy. It does this by winning a place on relevant UK public sector frameworks and then involving our network of over 200 subcontractors (“Partners”), almost all SMEs based in the UK (with a few global companies trading in the UK, and a few others based in Europe or USA), to secure and deliver contracts.
The rest of this statement focuses on Bramble Hub, although some items apply to the whole group.
Our policies in relation to slavery and human trafficking
Our anti-slavery policy is managed and maintained (reviewed and updated as appropriate) as part of our Quality and Environmental Management System (QEMS), which is subject to internal audit and external ISO audit and certification. The policy (which applies to the whole group) reflects our commitment to acting ethically and with integrity in all our business relationships, helping to ensure that slavery and human trafficking is not taking place anywhere in our business.
It confirms that, as a matter of policy, we:
- Do not use forced, bonded or involuntary prison
- Do not allow our subcontractors to use forced, bonded or involuntary prison labour (which we are contractually enforcing where we can for new contracts).
- Do not require any of our staff or our subcontractors’ staff to lodge deposits or identity papers with their employer, and that staff are free to leave their employer after reasonable notice
- Have working due diligence procedures to manage and reduce the risk of slavery or human trafficking in our supply chain performing obligations.
- Do not use, and do not allow our employees or subcontractors to use, physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation of our employees or subcontractors. Our employment contracts and associated employment policies and procedures ensure our employees are not allowed to do
- Do not use or allow child or slave labour to be used by our
- Would report the discovery or suspicion of any slavery or trafficking by us or any of our subcontractors to relevant customers and the Modern Slavery Helpline, if the situation All employees and partners understand that they have a statutory obligation to report knowledge or suspicion of slavery or human trafficking and may do so without fear of discrimination or reprisal.
Related policies and procedures
As part of our internal audit process, we regularly review and updat our other relevant policies and procedures (for the whole group) to ensure they include references to modern slavery and human trafficking where relevant. These include:
- Equal Opportunities and Diversity Policy
- Ethical Purchasing policy
- Partner Risk Management
The overall responsibility for the policies lies with the Managing Director.
Due diligence processes
We have:
- Undertaken an annual Modern Slavery Risk Assessment for ourselves (our whole group) and our supply chains. The conclusions have been included in this Statement and will continue to be reviewed annually.
- Reviewed the policies, procedures and templates within our ISO 9001 quality management system (QMS) and employee policy/procedure handbook (for the whole group), updated them as necessary (no changes required), communicated to all staff, and added to our internal audit schedule to ensure that they form part of the annual quality management review.
- Made reasonable enquiries (across the group) to ensure our officers (directors), employees and subcontractors have not been convicted of slavery or human trafficking offenses anywhere around the world.
- Reviewed our subcontracts (for the group), ensuring appropriate anti-slavery and anti-trafficking clauses are included and/or flowed down as appropriate. All our subcontracts flow down responsibilities and commitments from government framework
- Confirmed that our partners are annually signing our online form to confirm their ongoing commitment to compliance with the Modern Slavery Act 2015 as part of the partnership registration process and before they can participate on Bramble Hub contracts. This confirms that they conform to the following principles:
- That their company does not use, nor allow any of its subcontractors to use, forced, bonded, or involuntary prison labour.
- That their neither their company nor any of its employees, directors, officers and any personnel involved in the delivery of the Services under a Contract has been convicted of any slavery or human trafficking offences anywhere around the world.
- That their company does not use, nor allow any of its employees, officers or subcontractors to use physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation of its employees or
- That their company does not use, nor allow any of its subcontractors to use, child or slave
This annual form, signed by an appropriate authority from within the subcontractor, gives us a formal record to evidence the ongoing compliance of our supply chain.
Risk assessment
The assessment of the potential for slavery or human trafficking in our organisation and our supply chains is judged to be VERY LOW, based on our small, owner-managed company, the work we do and the suppliers we work with.
Training on modern slavery and trafficking
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we include our Modern Slavery Policy and Statement in the induction training for new employees. All staff are required to read and confirm their understanding of our current Statement, as part of our annual refreshment training programme.
Key performance indicators to measure effectiveness of steps being taken
We have incorporated the following Key Performance Indicators (KPIs) into our regular internal audit checks:
- All partners’ online commitments to Modern Slavery principles are up to date
- No reports received of slavery or human trafficking
- All staff aware of the risks of modern slavery and human
This voluntary slavery and human trafficking statement is made in connection with section 54(1) of the Modern Slavery Act 2015. It was approved by the board on 4th August 2026.
SIGNED by:
Richard Archer, Managing Director
Date: 4th August 2026
