As a forward-leaning company, we have a responsibility to take a longer-term perspective of what it means to champion and enable positive change. We continue to consider the broader impact of our actions to ensure we are upholding our commitment to our team, our supplier ecosystem, our customers, and, most importantly, our society.

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We are committed to minimising our environmental impact. From the energy powering our facilities to our waste management processes, we are constantly looking for ways to reduce our footprint. We have invested in sustainable infrastructure including free EV chargers for staff and visitors, offer a variety of incentives and facilities for low carbon travel, and operate a carbon offsetting initiative with Ecologi.

Environment

As a business specialising in solving complex problems we actively encourage different ways of thinking. We believe that an inclusive workplace that draws upon diverse skills, experiences, and perspectives is better placed to support our clients' infinitely varied needs. Our inclusive policies, facilities, and outreach programmes help us draw talent from the widest possible pool, and we are signatories of the Tech Talent Charter and Armed Forces Covenant, championing inclusion of underrepresented groups.

Equality, Diversity, and Inclusion

We believe the health and wellbeing of staff is foundational in creating a positive and productive workplace. We have introduced a range of initiatives to support our teams, such as private healthcare, which is available to all employees at all grades and includes mental health support. Our trained Mental Health First Aiders are also on hand if needed, and for those looking to work up a sweat we even offer an on-site gym.

Health and Wellbeing

Rowden is committed to taking steps to combat modern slavery and human trafficking and comply with our obligations under the Modern Slavery Act 2015 (“the Act”). We take a zero-tolerance approach to non-ethical practices and are committed to acting professionally, fairly, and with integrity in all our business dealings and supply chain relationships, wherever we operate, implementing and enforcing effective systems to uphold ethical standards and to combat modern slavery and human trafficking.

Modern slavery is an international crime affecting over 40 million people around the world. This growing global issue transcends age, gender, and ethnicities. It includes victims trafficked from overseas and vulnerable people in the UK who are forced illegally to work against their will across many different sectors such as agriculture, hospitality, construction, retail, and manufacturing.

The Act seeks to address the role of businesses in preventing modern slavery occurring in their supply chains and organisations. As Rowden is an SME trading below the turnover threshold indicated by law, it is not required to make a formal statement, however, we recognise that our customers will be seeking reassurance from us about our commitment to this problem.

This statement sets out the steps that we have and will continue to take as part of our ongoing commitment to keep slavery and human trafficking out of our business and our supply chains.

Rowden is a UK-headquartered engineering business. We build and integrate advanced systems that sense, connect, and protect data in demanding environments where decisions must be made quickly. Our solutions use intelligent automation for speed and efficiency and are designed to be straightforward and reliable for those operating in critical or remote settings. 

Supply chain activities at Rowden include the procurement of goods (e.g. equipment, components), labour (e.g. contracted workers) and services (e.g. facilities contracts) required for our business. We have a global supply chain, primarily UK-based, which also includes a smaller number of suppliers from North America and Europe. Our supply chain includes larger hardware and technology providers as well as third-party associates and consultants, SMEs, and local businesses that have the requisite technical skills and qualifications to help us deliver our services.

We have assessed the risks linked to modern slavery (i.e. high-risk sectors, lack of regulation in source countries, complex employment arrangements, presence of vulnerable workers, absence of worker representation and rights) and we believe that the nature of our business means that the risk of modern slavery and human trafficking is low. For example, we have limited use of labour suppliers, we do not have complex global supply chains, and we do not operate in a context of high flexibility and low profit margins. We do not rely on cheap labour, vulnerable workers, or seasonal workers. Nevertheless, we are committed to taking steps to uncover any potential risks within its supply chain.

We have several procedures in place that contribute to ensuring modern slavery does not occur in our business or supply chains. We will regularly review our internal practices and our supply chain to ensure that our zero-tolerance policy in respect of human trafficking and modern slavery is being upheld.

We recognise that tackling modern slavery requires a continuing, year-on-year commitment and will continue to undertake due diligence in our supply chain and review and improve procedures to help identify and prevent the risks of modern slavery or human trafficking.

During the next financial year, we aim to identify, assess, and manage risks on an ongoing basis by gathering additional information from suppliers during the procurement and audit processes regarding their awareness of, and compliance with, the Act, and endeavour to ensure that appropriate contractual provisions are incorporated into supplier contracts.

Modern Slavery and Human Trafficking Statement

Corporate integrity and responsible sourcing are of paramount importance to Rowden. These core principles are reflected in this Supplier Code of Conduct (Code), which establishes the minimum standards that must be met by any entity that supplies products or services to Rowden.

All Suppliers to Rowden shall comply with the Code and shall ensure that their Workers and Representatives are aware of this Code and comply with it. Any obligation or expectation on a Supplier in this Code shall also include an obligation for the Supplier to step down such obligation to their own workforce and supply chain (Representatives).

Rowden has the right to modify this Code from time to time. The current version of this Code is available on Rowden’s website.

1.1	Suppliers shall comply with all applicable laws and regulations when providing services and/or goods to Rowden. This shall include both compliance with UK laws, and the laws and regulations of any other jurisdiction where the Supplier or its Representatives operate.

1.2	Suppliers shall ensure compliance with the Official Secrets Act 1989 and the National Security Act 2023.

1.3	Suppliers shall comply with the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) and the Data (Use and Access) Act 2025 as they apply in the UK, and the General Data Protection Regulation 2016/679 where applicable, together with any and all other applicable laws, regulations or other statutory instruments relating to the protection of personal data in any other applicable jurisdiction.

2.1	Suppliers shall not permit, in their own organisation or across their Representatives, Workers being subject to forced, trafficked or compulsory labour in any form. Suppliers shall comply with all applicable anti-slavery and human trafficking laws and codes, including the Modern Slavery Act 2015. 

2.2	Suppliers shall ensure that Workers are not required to repay debt through work and/or make payments which have the intent or effect of creating workplace slavery.

2.3	Suppliers shall ensure that Workers’ terms of employment or engagement shall be documented in writing in a way which clearly articulates their rights and obligations. This should include clear details of wages and overtime pay, working hours and rights in respect of rest breaks and holiday. The document should be provided to the Worker prior to commencement of employment and should comply with good industry practice and all applicable laws. 

2.4	Suppliers shall ensure that Workers have the right to terminate their employment freely and without improper penalty, following a reasonable period of notice in accordance with applicable laws and collective agreements.

2.5	Suppliers shall ensure that Workers have access to information regarding their rights under anti-slavery and human trafficking legislation and are able to file grievances regarding their employer’s treatment of them. They should not suffer victimisation or detriment as a result of raising a complaint regarding their treatment.

2.6	Suppliers shall not hinder Workers’ rights to legally organise and join associations such as trade unions.

2.7	Suppliers shall ensure that Workers are not subject to harsh or inhumane treatment, including but not limited to physical punishment, violence or coercion, verbal abuse, harassment or intimidation.

2.8	Suppliers shall ensure that Workers are free to move without unreasonable restrictions and shall not be physically confined to their place of work or any other location. 

2.9	Suppliers shall ensure that migrant workers are not subject to any discrimination due to their race or nationality.

2.10	Suppliers shall not use any form of child labour. Suppliers shall not employ any individual under the minimum legal age of employment. Subject to the overriding prohibition on child labour, in respect of Workers under the age of 18, particular care shall be taken as to their working conditions and the duties they carry out to ensure that they come to no harm as a result of their working conditions and/or work.

3. Discrimination and Treatment of Workers

3.1	Rowden is an equal opportunities employer and expects the same of its supply chain. Suppliers shall treat all Workers fairly and shall not discriminate based on age, gender, sexual orientation, race, ethnicity, colour, disability, religion, political affiliation, union membership, national origin, marital or pregnancy status, subject always to any accommodations required or permitted by law. 

3.2	Suppliers shall ensure they undertake a discrimination-free recruitment processes, providing fair and equal opportunities to all applicants.

3.3	Suppliers shall provide a harassment-free working environment. Any forms or threats of harassment (physical, mental, sexual, or verbal) must be prohibited. 

3.4	Suppliers shall ensure that all wages and benefits paid to Workers meet legal minimums and are paid without unauthorised deductions. 

3.5	Suppliers shall ensure that Workers’ working hours comply with law, and should not expect Workers to work beyond the hours set out in relevant working time legislation unless an opt out has been chosen by the employee. 

3.6	Suppliers shall provide safe working conditions for all Workers. 

3.7	Suppliers shall ensure that health and safety is effectively managed, so that all associated risks, issues, incidents, and non-compliance are identified, addressed, and eliminated where possible.

4.1	Rowden does not tolerate any form of bribery or corruption. This includes the offering, paying, soliciting, or accepting of bribes (including facilitation payments) which are strictly prohibited. Suppliers shall implement anti-corruption and bribery procedures which aim to prevent its Workers or other persons associated with their business from committing offences of bribery or corruption. Such procedures shall be regularly reviewed to ensure they are appropriate, proportionate and effective.

4.2	A bribe may involve giving or offering any form of gift, consideration, reward, or advantage to someone in business or government in order to obtain or retain a commercial advantage or to induce or reward the recipient for acting improperly or where it would be improper for the recipient to accept the benefit. Bribery can also take place where a bribe is offered or made by or through a third party.

4.3	The following list is not exhaustive, but some examples of bribes are as follows:

4.4	Facilitation payments are strictly prohibited. These include small payments or fees requested by government officials to speed up or facilitate the performance of routine government action (for example, the provision of a visa).

4.5	Suppliers shall comply with all applicable anti-bribery and corruption laws, including, as a minimum, the requirements set out in the UK Bribery Act 2010.

5.1	Suppliers shall comply with all applicable tax laws, and shall not engage in any activity, practice, or conduct which would constitute an offence under Part 3 of the Criminal Finances Act 2017 in respect of tax evasion (whether in the UK or abroad).

5.2	Suppliers shall have adequate policies and procedures in respect of prevention of tax evasion, fraud and money laundering, and shall enforce such policies where appropriate.

5.3	Suppliers shall maintain adequate records regarding their compliance with tax and finance laws.

6.1	Rowden conducts its business in a sustainable and proportionate way, with the aim of minimising any negative impacts through supporting and encouraging sustainable operating practices. Suppliers shall continually strive towards improving the sustainability of their operations, from an environmental, social, and economic perspective.

6.3	Suppliers shall comply with all applicable health and safety and environmental regulations, including those relating to the procurement, storage, handling of dangerous and hazardous materials, and the production of packaging and disposal of waste. Any necessary permits, licenses and registrations shall be obtained, maintained, and kept up to date.

6.4	Suppliers shall fulfil all sustainability reporting requirements agreed with Rowden, including supplying data for any monitoring or measuring criteria agreed at the beginning of the contract.

6.5	On request, Suppliers should be able to demonstrate to Rowden how they assess whether they are a sustainable business.

7.1. Suppliers shall uphold the highest standard of integrity in the work they do with Rowden, including duly disclosing any actual, potential or perceived conflicts between their own interests and the interests of Rowden and its customers (where applicable) (conflicts of interest).

7.3. If the Supplier identifies a conflict of interest, they must:

8.1. Suppliers shall comply with Rowden’s Supplier onboarding and management processes, including but not limited to:

8.1.1. Providing full, transparent and accurate information on request and when completing Rowden’s Supplier Management Questionnaire;

8.2. Supplier acknowledges that failure to comply with the provisions within this section 8 may result in the suspension or termination of the contract between the Supplier and Rowden.

9.1. Suppliers shall comply with all applicable export control, trade control and economic sanctions laws and regulations in any jurisdiction in which they operate or which apply to the goods, software, technology or services supplied to Rowden.

9.2.  Where applicable, Suppliers shall also comply with any relevant international export control and sanctions regimes that may apply to the performance of the contract.

9.4.  Suppliers shall maintain appropriate policies, procedures and internal controls designed to ensure ongoing compliance with export control and sanctions laws. This shall include, where appropriate, risk assessments, screening of relevant counterparties against applicable sanctions lists, and the maintenance of accurate records relating to export classifications and licences.

9.5. Suppliers shall obtain and maintain all necessary licences, consents, permits and authorisations required for the export, transfer or provision of goods, software, technology or services supplied in connection with Rowden, and shall comply with all conditions attached to such licences or authorisations. 

9.6. Suppliers shall promptly notify Rowden in writing if:

9.7. Suppliers shall provide such reasonable assistance, information and documentation as Rowden may require to verify compliance with this Section 8, including evidence of export classifications.

10.1. Suppliers shall ensure there is a system of adequate training for their Workers to ensure that they are aware of the requirements of this Code. 

10.2. Suppliers shall keep training records and shall make copies of such records available to Rowden on request. 

10.3. Suppliers shall provide written confirmation to Rowden at least annually that: 

10.4. Suppliers shall promptly provide any self-certifications that are reasonably required by Rowden to demonstrate compliance with all applicable laws.

10.5. Rowden may conduct audits and inspections to verify a Supplier's compliance with this Code. The Supplier shall provide reasonable assistance to Rowden in relation to such audits. 

10.6. Suppliers shall report any breaches (actual or suspected) of this Code as soon as possible to Rowden’s General Counsel.

10.7. Suppliers shall not retaliate or take disciplinary action against any Worker that has, in good faith, reported breaches of this Code, or sought advice regarding this Code.

A business that sees further than products and profits.

Environment

Equality, Diversity, and Inclusion

Health and Wellbeing

Modern Slavery and Human Trafficking Statement

Supplier Code of Conduct