Modern Slavery Act

TCW — The Compliance Workbook Ltd, trading as TCW, registered in England and Wales under company number 08760486, with its registered office at 5 Bridge Street, Birkenhead, Wirral CH41 1AS — takes a zero-tolerance approach to modern slavery, slavery, human trafficking, forced labour, child labour, domestic servitude and debt bondage in any form.

We are not a commercial organisation obliged to publish a statement under section 54 of the Modern Slavery Act 2015, which applies to organisations above a specified annual turnover. We publish this statement voluntarily, so that clients, partners and prospective suppliers can see what we do and what we expect of them.

This statement covers the twelve months to 15 October 2026. It sets out our operations and supply chains, the policies and checks we apply, the risks we have identified and the training and reporting routes we provide. It is reviewed and republished at least annually.

TCW is a UK technology company. We develop and operate software for compliance and risk management in the built environment, and we provide engineering-led assurance, data and evidence services to housing providers, local authorities and other organisations managing property and estates.

Our workforce is office and homework based, and our operations are largely in the United Kingdom, with some activity in Northern Ireland and the Republic of Ireland. All staff are recruited directly by TCW, and we do not use agency or labour-only workers in our operations.

Our supply chain is relatively short and mostly low risk. It consists of:

• cloud hosting, data and software providers;
• professional services such as legal, accountancy and insurance advisers;
• marketing, design, film, events and print suppliers;
• office services, stationery and equipment suppliers; and
• contractors and consultants engaged for specific projects.

Where a supplier sits outside the United Kingdom, or where we cannot see how the work is actually carried out, we treat it as higher risk and apply more scrutiny.

Our approach is governed by a small set of internal policies and controls, which are kept under review by the directors:

• Supplier code of conduct — suppliers are expected to pay at least the appropriate minimum wage, respect working-hours limits, use their own employed staff or properly licensed agencies, and prohibit forced labour, retention of identity documents, recruitment fees and any form of trafficking.
• Recruitment and vetting — we verify the right to work of every employee and contractor before they start, recruit only through reputable channels, and never charge anyone a fee to work with us.
• Whistleblowing — staff can raise concerns confidentially without fear of detriment, including concerns about a supplier.
• Contracts — our standard supplier terms include compliance with the Modern Slavery Act 2015 and the right to audit or terminate where a supplier fails to meet those obligations.

Day-to-day ownership of this statement sits with the directors, who approve it and review it annually.

We assess modern slavery risk in two steps. First we look at our own operations: our people are recruited directly, their identity and right-to-work documents are checked, pay is made through the bank from TCW payroll, and working hours and conditions are governed by our employment policies. We consider the inherent risk in our own operations to be low.

Second we look at our supply chain. Before appointing a supplier we consider where the work is done, whether the supplier is well known and established, whether it publishes its own modern slavery statement or equivalent policies, and whether the price and timescale being offered are credible. For higher-risk suppliers we ask for written confirmation of their labour and recruitment practices.

The risks we monitor most closely are:

• overseas suppliers providing development, support or data-processing services, where working conditions are further from our view;
• event, exhibition, build, catering and cleaning work at third-party venues, where the venue rather than TCW controls the labour; and
• hardware, device and print supply chains, where lower-cost components and materials can carry labour abuse risk further up the chain.

No instance of modern slavery has been identified in TCW's operations or supply chains during the period covered by this statement.

Directors and staff who commission or manage suppliers are made aware of the indicators of modern slavery — for example workers who appear to be controlled, unpaid or in debt to an employer, withheld identity documents, excessive overtime, or recruitment fees — and of how to escalate what they see. Awareness of this statement is included when staff join TCW.

If we find evidence of modern slavery in our own operations, we will act immediately to protect those affected, end the practice and, where appropriate, report it to the police, the National Referral Mechanism or the relevant authority. Where the concern sits with a supplier, we will expect the supplier to act and to keep us informed, and we will terminate the relationship if the supplier is unwilling or unable to put things right.

Anyone — employee, contractor, supplier, client or member of the public — can raise a concern with TCW in confidence by emailing info@TCWin.co.uk. Concerns are handled by the directors. We do not tolerate retaliation against anyone who raises a concern honestly.

This statement has been approved by the directors of The Compliance Workbook Ltd and is published on the TCW website at www.TCWin.co.uk/modern-slavery-statement. It will be reviewed and republished at least annually, and sooner if our operations or supply chains change in a way that affects the risks described here.

Published 27 October 2026.