Modern Slavery Statement

Introduction

Medly AI Limited ("Medly") is a UK-based educational technology company founded in 2023. Although Medly's annual turnover is below the £36 million threshold at which section 54 of the Modern Slavery Act 2015 imposes a mandatory statement, we believe the principles set out in section 54 represent best practice and we choose to publish this voluntary statement in line with them. We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, child labour and any form of human exploitation in our business or supply chain.

Our structure and business

Medly AI Limited is registered in England and Wales (Companies House 15110302). The registered office is 85 Great Portland Street. The business develops and operates AI-powered tutoring software for secondary-school pupils and their teachers, served over the public internet. We are a small team operating remote-first from the UK, with no overseas offices, no manufacturing operations and no physical retail or distribution footprint.

Our supply chains

Medly's supply chain is concentrated in low-risk professional and digital services. The main categories are:

  • Cloud and AI infrastructure — services from established providers (e.g. Google Cloud, Microsoft, Amazon Web Services, Anthropic, OpenAI) operating under public commercial terms in jurisdictions with strong labour-law regimes.
  • Office services and utilities — leased office space, electricity, utilities and waste services in the United Kingdom.
  • Professional services — legal, accounting, insurance, payroll, payment processing and security testing, all provided by UK-regulated firms.
  • Software-as-a-Service tooling — observability, analytics, communications, productivity and CRM tooling.
  • People — Medly's team are employed or engaged directly under UK law; agency and contractor engagements are with UK-registered entities operating to UK employment standards.

Medly does not procure physical goods at material volume, does not operate in high-risk geographies, and does not source raw materials, garments, agricultural products or hand-finished goods. The residual modern-slavery risk in the supply chain is therefore assessed as low; the principal residual exposure is in sub-contracted office and cleaning services within the leased office building (managed by the landlord) and, to a lesser extent, in the upstream hardware supply chain of cloud providers.

Our policies

The following policies set out our position and the standards we expect of those who work with us:

  • Modern Slavery and Human Trafficking Policy (this document together with internal procedures).
  • Code of Conduct, applicable to all employees, contractors and directors.
  • Whistleblowing Policy providing a confidential channel for raising concerns, including concerns about exploitation in our supply chain.
  • Equality, Diversity and Inclusion Policy.
  • Safer Recruitment and Right-to-Work checks for all hires.
  • Supplier engagement standards: suppliers above a defined value threshold are required to confirm compliance with the Modern Slavery Act 2015 and equivalent obligations.

Due diligence processes

Before engaging any new supplier of professional or technology services, Medly:

  • Verifies that the supplier is a legal entity in good standing in its registered jurisdiction.
  • For suppliers above £36m turnover, reviews their published Modern Slavery Statement.
  • For smaller suppliers, requires a contractual representation that the supplier complies with all applicable employment, anti-slavery and human-trafficking laws.
  • Reviews the engagement annually, or sooner where there is a material change in service or in the supplier's circumstances.

All employment offers are subject to right-to-work verification under the Immigration, Asylum and Nationality Act 2006. New hires are paid through a UK-regulated payroll provider and receive a written contract setting out their entitlements.

Risk assessment

Medly conducts an annual modern-slavery risk assessment covering: (a) the geographic risk of countries in which the business operates and from which the team is drawn; (b) the sectoral risk of the categories of supplier we engage; and (c) the size and visibility of each tier of supplier. The 2025/26 assessment concludes that Medly's direct supply-chain risk is low. The most material remaining areas of attention are: hardware manufacturing within the upstream supply chains of our cloud providers (mitigated by procuring from established providers with published statements); cleaning and facilities services in the landlord-managed office building (mitigated by the landlord's own statement and our right to escalate concerns).

Training and awareness

All Medly staff receive induction on the Code of Conduct, including signs of modern slavery and trafficking and how to raise concerns. Senior leaders responsible for procurement and supplier management receive training on supply-chain due diligence and on conducting effective annual reviews.

Measuring effectiveness

We measure the effectiveness of these arrangements through the following indicators:

  • Number of new and renewed supplier engagements reviewed against modern-slavery criteria each year.
  • Number of concerns raised through the whistleblowing channel and time to resolution.
  • Number of staff completing modern-slavery induction or refresher each year.
  • Outcome of the annual modern-slavery risk assessment, including any new risks identified and the remediation actions taken.

No instances of modern slavery, human trafficking or forced labour have been identified within Medly or its supply chain during the reporting period.

Last updated: 9 April 2026