Modern slavery statement


This statement applies to Shearwater Group (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the current financial year.

Organisational structure

Shearwater Group’s aim is to acquire and develop information security, cyber and cyber security companies with a leading product, solution or service capability, whose full potential can be unlocked through active management and capital investment.

SWG is comprised of Xcina Consulting Limited, Geolang Limited, Pentest Limited, Brookcourt Solutions Limited, and SecurEnvoy Limited.

The Organisation has offices in the United Kingdom, in London, Altringham, Redhill, Basingstoke and Cardiff. It also operates in the USA and Germany.

The labour supplied to the Organisation in pursuance of its operation is carried out in the UK, USA and Germany.

3  Definitions

The Organisation considers that modern slavery encompasses:

  • human trafficking; 
  • forced work, through mental or physical threat;
  • being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
  • being dehumanised, treated as a commodity or being bought or sold as property;
  • being physically constrained or to have restriction placed on freedom of movement.

4  Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, the USA and Germany and in many cases exceeds those minimums in relation to its employees.

5  Supply chains

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.

6  Potential exposure

In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

7  Steps taken

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

• Right to work checks completed at recruitment stage;
• Ensure minimum employment age adhered to, in line with the relevant legislation;
• Always apply national minimum wage thresholds, in line with the relevant legislation;
• Regular contact with suppliers including their understanding of, and compliance with, our expectations;
• We have systems in place to encourage the reporting of concerns and the protection of whistle blowers

8  Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer, CEO Phil Higgins, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations. 

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year