Modern slavery statement 2026

Policy Owner : Dan Fountain
Effective date : 01/06/2023
Latest update : 02/09/2024

Contents:

1. Introduction
2. About IONA Commerce Ltd
2.1 Our Business model
2.2 Our supply chain
3. Scope
3.1.1 Modern Slavery Policy
3.1.2 Code of Conduct
3.1.3 Recruitment and HR Policy
3.1.4 Whistleblowing Policy
3.1.5 Supplier Code of Conduct
4. Risk assessment
5. Employee awareness, training and compliance
6. Monitoring and effectiveness

1. Introduction

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes IONA Commerce Ltd's Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2026.
IONA Commerce Ltd is firmly committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our business or supply chain.

Modern slavery is a crime and a violation of fundamental human rights. It takes many forms, including slavery, servitude, forced and compulsory labour, and human trafficking. We take our responsibilities under the Act seriously and this statement sets out the steps we have taken during the year to identify and address any risks.

2. About IONA Commerce Ltd

IONA Commerce Ltd is a specialist ecommerce systems integrator headquartered in Helsinki, Finland and with offices in the Philippines and in the United Kingdom. We work with retailers, brands and digital commerce teams to design, implement and support ecommerce technology ecosystems — connecting platforms, payment providers, logistics systems, and digital experience tools to help our clients trade effectively online.

2.1 Our Business model

Our business is primarily a professional services and technology consultancy.

We deliver:

  • Ecommerce platform implementation and integration projects
  • Systems architecture design and technical consultancy
  • Ongoing managed services and support for commerce technology stacks

2.2 Our supply chain

Given the nature of our business, our supply chain is relatively straightforward and low-risk. Our principal suppliers and partners include:

  • Software vendors and SaaS platform providers (e.g. platform licences, integration tools, cloud infrastructure)
  • Independent contractors and specialist technical consultants engaged in the Finland, Philippines and the UK
  • Professional services firms (legal, accountancy, HR)
  • Office services, equipment and facilities suppliers

We do not manufacture physical goods, and we do not have international manufacturing, logistics or distribution supply chains.

3. Scope

This policy applies to all employees at IONA, and to all those who work on our behalf in any capacity.

3.1 Policy Statement

We maintain a suite of internal policies that reflect our commitment to operating ethically and in compliance with applicable law. The following policies are directly relevant to our approach to modern slavery and human trafficking:

3.1.1 Modern Slavery Policy

Our Modern Slavery Policy sets out our zero-tolerance approach to modern slavery in all forms and applies to all persons working for us or on our behalf in any capacity. It sets out the responsibilities of staff to report any concerns and the processes by which those concerns will be investigated.

3.1.2 Code of Conduct

Our Code of Conduct establishes the ethical standards expected of all employees, contractors and business partners. It explicitly prohibits forced, compulsory or trafficked labour, and child labour. It applies equally to our conduct and to those we work with.

3.1.3 Recruitment and HR Policy

We recruit staff and engage contractors only through reputable, vetted channels. We verify the right to work for all employees in accordance with UK law and do not use unlicensed labour providers. We pay at least the National Living Wage and comply with all applicable employment legislation.

3.1.4 Whistleblowing Policy

Our Whistleblowing Policy encourages employees and contractors to raise concerns about any wrongdoing, including suspected modern slavery, without fear of retaliation. Concerns can be raised confidentially with our management team.

3.1.5 Supplier Code of Conduct

We expect all suppliers and business partners to adhere to our Supplier Code of Conduct, which incorporates our expectations on labour standards, human rights, and ethical business practice

IONA demands the same high ethical standards to be upheld by all business partners and that they respect our pledge to eradicate modern slavery.

4. Risk assessment

We regularly review our operations and supply chains to identify any potential risks of modern slavery and human trafficking.

We recognise that our supply chain may evolve as we grow, and that new vendor relationships — particularly international software providers or outsourced technical services — could introduce incremental risk. We commit to reviewing our risk assessment annually and updating our controls accordingly.

5. Employee awareness, training and compliance

IONA takes full responsibility in ensuring that all employees throughout the company are firmly aware of our demand for ethical practices in accordance with The Modern Slavery Act.

All employees are required to read, understand, and accept this policy and affirm their commitment to upholding our high standards of workplace ethics, behaviour, and human rights.

Managers are responsible for ensuring all those that report to them understand and comply with this policy, and provide regular training wherever necessary.

We require employees to report to line management any issue or suspicion of modern slavery in any aspect of our business operations or supply chain.

6. Monitoring and effectiveness

Our policies and procedures are reviewed regularly to ensure they are effective in addressing any potential risks.

We will converse with new and existing business partners to identify risk areas which may arise and discuss where improvements can be made if failures are identified.

Refusal to comply will result in the termination of business relationships
Any employee who breaches our policy will face disciplinary action which may result in dismissal for gross misconduct.