Financial Year: 2024/2025 | Published: December 2025
Introduction
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Belvyon Limited has taken, and continues to take, to ensure that modern slavery and human trafficking is not taking place within our business or supply chains.
Our Commitment
Belvyon Limited has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
1. Company Structure and Supply Chains
Our Organisation
Belvyon Limited is a UK-registered company (Company Number 16762038) specialising in advanced materials for defence and aerospace applications. We are headquartered at The Hangar, Hadley Park East, Telford, TF1 6QJ, United Kingdom.
Our Business Activities
- Research and development of advanced materials
- Design and engineering of defence and aerospace solutions
- Manufacturing partnerships with UK-based suppliers
- Sales and technical support to defence and commercial customers
Our Supply Chains
Our supply chains include:
Raw Materials
Specialist materials and chemicals sourced primarily from UK and EU suppliers with established quality certifications.
Manufacturing Partners
UK-based manufacturing partners qualified to defence and aerospace standards.
Equipment & Services
Testing equipment, professional services, and IT infrastructure from established UK and international suppliers.
Logistics
Secure logistics providers for sensitive materials and finished products.
2. Policies in Relation to Slavery and Human Trafficking
We operate the following policies that contribute to ensuring modern slavery does not occur in our business:
| Policy | Purpose |
|---|---|
| Anti-Slavery and Human Trafficking Policy | Sets out our commitment to preventing modern slavery, provides guidance on identifying risks, and establishes reporting procedures. |
| Supplier Code of Conduct | Requires all suppliers to confirm they do not use forced, bonded, or involuntary labour and that they comply with all applicable laws regarding slavery and human trafficking. |
| Whistleblowing Policy | Encourages employees and others to report concerns about unethical conduct, including any suspicion of modern slavery, without fear of retaliation. |
| Recruitment Policy | Ensures robust procedures for verifying the identity, right to work, and employment history of all employees to safeguard against human trafficking. |
| Ethical Procurement Policy | Establishes ethical standards for supplier selection and ongoing management, including human rights considerations. |
3. Due Diligence Processes
We undertake due diligence when considering taking on new suppliers and regularly review existing suppliers to ensure they meet our standards:
Supplier Due Diligence
- Supplier questionnaires including modern slavery compliance questions
- Review of supplier policies and procedures
- Assessment of supplier location and associated country-level risks
- Verification of certifications and accreditations
- Site visits to key suppliers where appropriate
Ongoing Monitoring
- Regular supplier performance reviews
- Monitoring of adverse media and sanctions lists
- Requirement for suppliers to notify us of any material changes
- Periodic reassessment of supplier risk profiles
Contractual Requirements
Our standard terms and conditions require suppliers to comply with all applicable laws, including the Modern Slavery Act 2015, and to have their own policies and procedures in place to ensure compliance within their supply chains.
4. Risk Assessment
We assess the risk of modern slavery occurring in our business and supply chains by considering:
Geographic Risk
Countries where suppliers operate, considering indices such as the Global Slavery Index and country-specific human rights reports.
Sector Risk
Industry sectors known to have higher prevalence of modern slavery, such as raw material extraction and low-skilled manufacturing.
Business Model Risk
Business models that may increase risk, such as use of temporary labour, subcontracting, or complex multi-tier supply chains.
Transaction Risk
Transaction characteristics that may indicate risk, such as unusual payment requests or reluctance to provide information.
Our Risk Profile
As a UK-based company primarily working with UK and EU suppliers in the regulated defence and aerospace sector, we consider our direct exposure to modern slavery risk to be relatively low. However, we remain vigilant and continue to monitor our supply chains, particularly for raw materials sourced from regions with higher risk profiles.
5. Performance Indicators
We use the following key performance indicators (KPIs) to measure our effectiveness in ensuring modern slavery is not occurring in our business or supply chains:
| KPI | Target | Status |
|---|---|---|
| Supplier compliance questionnaires completed | 100% of new suppliers | On Track |
| Staff training completion rate | 100% of relevant staff | On Track |
| Modern slavery clauses in supplier contracts | 100% of contracts | On Track |
| Reported incidents of modern slavery | Zero tolerance | Zero Incidents |
| Annual policy review completed | Completed annually | Complete |
6. Training
We provide training to our staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and supply chains:
- Induction Training: All new employees receive training on our policies, including our approach to preventing modern slavery
- Procurement Training: Staff involved in procurement and supplier management receive specific training on identifying modern slavery risks and conducting due diligence
- Management Training: Senior management receive training on their responsibilities under the Modern Slavery Act 2015
- Refresher Training: Annual refresher training for all relevant staff to maintain awareness
Training Content
Our training covers the definition of modern slavery and human trafficking, how to identify potential indicators, our reporting procedures, and the consequences of non-compliance for both individuals and the company.
7. Reporting Concerns
If you have any concerns about modern slavery in relation to Belvyon Limited or our supply chains, we encourage you to report them:
Postal Address
Compliance Officer
Belvyon Limited
The Hangar, Hadley Park East
Telford, TF1 6QJ, United Kingdom
All concerns will be investigated and appropriate action taken. We will not retaliate against anyone who raises a genuine concern in good faith.
Approval
This statement has been approved by the Board of Directors of Belvyon Limited and is signed by a director of the company.
Signed:
Dr Belgin Elmas
Position: Managing Director
Company: Belvyon Limited
Date: December 2025
This statement will be reviewed and updated annually in accordance with Section 54 of the Modern Slavery Act 2015.