Modern slavery and human trafficking statement

Modern slavery and human trafficking statement

Although Studee is not required by section 54 of the Modern Slavery Act 2015 to publish a transparency statement - our annual turnover sits below the £36 million threshold the Act applies to - we publish one voluntarily. We work in international education, where students and families cross borders to engage with universities. That sector has well-documented modern-slavery and human-trafficking risks, and our partners increasingly expect their suppliers to be transparent about how those risks are managed. Publishing a statement we are not legally required to publish is the simplest way for us to be honest about that, and to be held to it.

This statement is structured to follow the six areas recommended in the Home Office statutory guidance on transparency in supply chains, issued under section 54(9) of the Modern Slavery Act 2015. Where our programme is still maturing, we say so plainly rather than overstating it.

Organisational structure and supply chains

Studee Ltd is a private limited company registered in England and Wales (company number 06842641) and headquartered in England. We operate studee.com - a public match-and-discover website that helps prospective international students explore university programmes.

We are a small organisation. We do not own physical manufacturing operations and we do not procure goods through complex multi-tier supply chains. Our supply chain is dominated by digital services and professional services. The supplier categories most relevant to this statement are:

  • cloud hosting and infrastructure providers
  • email and notification delivery services
  • analytics and product-instrumentation tooling
  • payment processing services, where applicable
  • marketing and advertising platforms
  • professional services (legal, accounting, recruitment)

Alongside our suppliers, we work with universities, which provide programme data and other reference material that we display.

Policies

We maintain the following policies, which together set our position on modern slavery and the related conduct expectations we hold ourselves and our partners to:

We have a zero-tolerance position on modern slavery, forced labour, servitude and human trafficking in any part of our operations or our supply chain. We expect the same of the suppliers and partners we work with.

Due diligence

Our due-diligence approach is proportionate to the size and shape of our supply chain. In practice, that means:

  • we contract primarily with established providers of digital and professional services that operate in jurisdictions with mature labour-rights regimes
  • we review new suppliers before onboarding for obvious red flags, including any credible reports of forced-labour or trafficking issues
  • our partner agreements with universities require those partners to comply with applicable law, which includes anti-slavery and anti-trafficking law in the jurisdictions where they operate.

We do not currently run a formal recurring supplier audit programme specifically for modern-slavery risk. We are honest that this is an area where our programme is still maturing, and we are evaluating a lightweight annual supplier-attestation process for FY2026.

Risk assessment

The area of our operation we consider higher-risk for modern-slavery and human-trafficking exposure is:

  • Suppliers with offshore operations, where labour conditions further down the chain are less visible to us. We mitigate this by preferring suppliers headquartered in jurisdictions with strong labour-rights enforcement and by reviewing each supplier's own published modern-slavery disclosures where one is available.

studee.com is an anonymous research and discovery site - visitors do not hold accounts and we do not facilitate movement of students between countries through the public site. Our exposure is therefore weighted toward our supply chain rather than our user base.

We do not currently produce a formal annual written risk assessment. Establishing a documented annual review is one of the items we are scoping for FY2026.

Training

Modern-slavery awareness is included in the general onboarding material we provide to new employees, with the goal that staff can recognise the indicators of forced labour and trafficking and know who to escalate concerns to. We do not currently run a recurring formal modern-slavery training course. We are evaluating training options for FY2026, with a view to introducing a short annual refresher for all staff.

Effectiveness and KPIs

We are establishing reporting baselines for the financial year ending 30 September 2026. For the first iteration of this statement, we are not yet publishing quantitative KPIs because we want any numbers we publish to reflect a measurement process we have actually run, rather than figures invented for the page. The areas we expect to baseline first are:

  • the proportion of new suppliers reviewed for modern-slavery red flags before onboarding
  • the number of modern-slavery concerns raised internally, and how each was handled
  • staff completion rate of the modern-slavery awareness module, once introduced.

Future versions of this statement will report against those baselines.

Raising a concern

Anyone - staff, supplier, partner, or member of the public - who suspects modern slavery or human trafficking in connection with Studee's operations or supply chain can raise it confidentially by contacting our Data Protection Officer. Concerns raised in good faith will not result in retaliation against the person raising them. Where a concern also amounts to a qualifying disclosure under the Public Interest Disclosure Act 1998 (which inserted Part IVA into the Employment Rights Act 1996), nothing in this statement limits the statutory protections that apply to the person making the disclosure.

Approval

This voluntary statement was approved by the Studee Ltd board on 12 May 2026 and signed by Simon Andrews (a director of Studee Ltd) on its behalf, in line with section 54(6) of the Modern Slavery Act 2015. It will be reviewed annually; the next scheduled review is 12 May 2027.