Modern Slavery & Human Trafficking Statement

1. Introduction

The Modern Slavery Act 2015 requires commercial organisations with an annual turnover above £36 million to publish a slavery and human-trafficking statement for each financial year. HULO Global Limited does not currently meet that turnover threshold; we nonetheless publish this statement voluntarilybecause we believe transparency and active stewardship of our supply chain are integral to the way we do business.

We do not tolerate forced, bonded or compulsory labour, child labour, human trafficking, or any other form of modern slavery in our own operations or in the operations of any business we contract with. We expect our suppliers to apply the same standard to their own people and to require it of theirs in turn.

2. Who we are

HULO Global Limited is a private company limited by shares, incorporated in England & Wales, with registered office at Unit A, 82 James Carter Road, Mildenhall, United Kingdom, IP28 7DE. We trade primarily under the elite brand at elite-software.co.uk, and operate a sister storefront at license-dock.com (LicenseDock).

We are a digital reseller. We sell software licences — predominantly from Microsoft, sourced through Microsoft's Cloud Solution Provider (CSP) programme and authorised distribution — to business and public-sector customers in the United Kingdom and Ireland. We do not manufacture hardware, do not maintain warehouses, do not employ staff outside the UK, and do not engage migrant or seasonal labour. The entirety of our trading entity is registered, banked and taxed in the United Kingdom.

3. Our supply chain

Our supply chain consists almost exclusively of large, publicly-traded software publishers and their authorised distribution partners (Microsoft Ireland Operations Limited, Microsoft's CSP indirect-provider channel, and a small number of UK / EEA authorised distributors). These suppliers are all subject to the Modern Slavery Act 2015 (or its equivalents) and publish their own statements that we review when onboarding a new supplier.

Beyond our software supply, our operational supply chain comprises:

• Cloud infrastructure providers (hosting, CDN, email);
• Payment processors regulated by the FCA and equivalents;
• UK-incorporated professional services (accountancy, legal, marketing);
• Telecoms and broadband providers.

All operational suppliers are headquartered in the UK, EEA, or other jurisdictions assessed by the Global Slavery Index as low-risk. We do not directly contract with suppliers in jurisdictions on the Index's highest-risk tier.

4. Risk assessment

Considering (a) the nature of our product (entirely digital, with no manufacturing or physical fulfilment), (b) the geographic concentration of our supply chain in the UK and EEA, and (c) the regulated nature of our principal suppliers, we assess our overall exposure to modern slavery risk as low.

The areas of residual risk we have identified, and our corresponding controls, are:

• Office cleaning & facilities — historically a higher-risk sector. We contract only with cleaning agencies that pay the real Living Wage and provide on-request evidence of right-to-work checks.
• Indirect technology distributors — we onboard only reputable indirect providers who themselves publish a Modern Slavery statement and operate a supplier code of conduct.
• Marketing merchandise — we do not commission bulk physical merchandise. Any limited-run printed goods are sourced from UK-incorporated suppliers with declared modern-slavery policies.

5. Our policies & procedures

We maintain the following policies, available to all employees and reviewed at least annually:

• Anti-slavery & human-trafficking policy;
• Supplier code of conduct (incorporating modern-slavery clauses);
• Whistleblowing / speak-up policy and confidential hotline;
• Recruitment policy (right-to-work checks, age verification, no document retention);
• Anti-bribery policy in compliance with the Bribery Act 2010;
• Equality, diversity & inclusion policy.

6. Employment practices

All staff are directly employed by HULO Global Limited under UK contracts of employment. We do not use third-party labour agencies for permanent roles. Our recruitment process includes:

• Right-to-work verification under the Home Office Employer's Guide;
• Age verification (no employee is engaged under 16);
• Direct payment of wages to bank accounts in the employee's own name;
• Written contracts of employment, available to the employee at all times;
• Annual pay review at or above the real Living Wage rate.

We retain none of an employee's identity documents beyond the verification step required by law.

7. Supplier due diligence

Before engaging a new supplier of material value to the business we:

• Verify the supplier's incorporation, registered office and Companies House filings (or equivalent);
• Review the supplier's most recent modern-slavery statement (or, where below threshold, written equivalent);
• Require written acceptance of our Supplier Code of Conduct;
• Record the assessment in our supplier register, reviewed at least annually.

Where a supplier cannot agree to comply with our Supplier Code of Conduct we work with them to bring their procedures into line with our standards; failing that, we discontinue the relationship.

8. Training & awareness

All staff with responsibility for procurement, supplier onboarding or human resources receive role-specific training on modern-slavery risk indicators and reporting obligations. Refresher training is delivered at least annually. New joiners complete the equivalent module within 30 days of starting.

9. Reporting concerns

Anyone — employee, supplier, customer or member of the public — who suspects modern slavery or human trafficking in connection with our business or our supply chain is encouraged to raise it. Reports may be made:

• By email, in confidence, to compliance@eliteenterprisesoftware.com;
• By post to the registered office above, marked “Compliance — Confidential”;
• To the UK Modern Slavery Helpline on 08000 121 700 (operated by Unseen UK, independent of us).

We will not retaliate against any person making a good-faith report.

10. Effectiveness & ongoing improvement

In the year covered by this statement, no allegation of modern slavery or human trafficking has been reported to us in respect of our operations or supply chain. We will continue to monitor and refine our approach, with reviews of our Supplier Code of Conduct, training programme and risk assessment built into our annual compliance cycle. The next review of this statement is due in June 2027.