GOVERNANCE & ETHICS

Modern Slavery Statement

Our commitment to ethical trading and the prevention of slavery and
human trafficking across our professional supply chain.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Cloudgap’s slavery and human trafficking statement for the financial year ending 2026.

As a specialist consultancy advising high-compliance sectors (Government, Defense, and Regulated Industries), we hold ourselves to the highest ethical standards. We voluntarily publish this statement to demonstrate transparency and alignment with the values of our clients and partners.

1. Our Structure & Business

Cloudgap is a UK-based cyber security and assurance consultancy. We provide strategic advisory services, including Managed vCISO, AI Governance, and Supply Chain Resilience.

Our workforce consists almost entirely of highly skilled professionals, senior consultants, and subject matter experts. Due to the nature of our business and the rigorous vetting required for our client work (including security clearances), the risk of modern slavery within our direct employee base is assessed as extremely low.

2. Our Supply Chain

Unlike manufacturing or retail, our supply chain is focused on professional services and digital tooling. We categorise our suppliers into three key areas:
  • Professional Associates & Partners: Independent consultants, legal counsel, and specialist technical partners who support our delivery.
  • SaaS & Digital Platforms: Software providers used for our internal operations, governance, and project management.
  • Corporate Services: Recruitment agencies, accounting firms, and office facilities management.

3. Policies & Due Diligence

We apply the same “Supply Chain Resilience” methodology to our own business that we deliver to our clients. Our approach to mitigating ethical risk includes:

Supplier Code of Conduct

We expect all partner consultancies and associates to adhere to our ethical standards. This includes a commitment to fair pay, voluntary labour, and compliance with all applicable UK labour laws.

Risk-Based Assessment

We conduct due diligence on all new suppliers. For recruitment agencies and associate partners, we verify their compliance with “Right to Work” checks and ensuring no hidden fees are charged to candidates.

Whistleblowing Policy

We maintain an open culture where employees and contractors are encouraged to report any concerns regarding unethical practices or working conditions. We protect whistleblowers from detrimental treatment.

4. Continuous Improvement

As our business grows, we remain committed to reviewing our policies annually. We will continue to:
  • Map our supply chain tiering to identify any emerging risks.
  • Ensure our contracts include clauses requiring suppliers to comply with the Modern Slavery Act 2015.
  • Provide awareness training to our leadership team on spotting the signs of modern slavery in the professional services sector.

5. Approval

This statement has been approved by the Board of Directors of Cloudgap and will be reviewed and updated annually.

Signed on behalf of the Board:

Director, Cloudgap
Date: January 2026

Last Updated: 25th January 2026