Varnham Consulting Ltd is committed to preventing modern slavery and human trafficking — both within the consultancy and across its supply chain. While the consultancy is not required to publish a statement under section 54 of the Modern Slavery Act 2015 (which applies to commercial organisations with annual turnover above £36 million), I publish this statement voluntarily as a matter of principle and to set out the standard expected of those I engage with.
Varnham Consulting Ltd is a UK-based data protection consultancy providing outsourced DPO services, compliance audits, training, and advisory support to UK SMEs. The consultancy operates as a sole practitioner with a small supply chain comprising:
The risk of modern slavery within Varnham Consulting Ltd's direct operations is assessed as low. The consultancy is UK-based, operates with a small number of professionally qualified personnel, and does not engage in low-skilled or high-volume labour activities.
The risk within the supply chain is similarly assessed as low. The supply chain is short, primarily comprises UK-based regulated professional services and major technology providers, and does not involve sectors typically associated with modern slavery risk.
I am committed to ensuring there is no modern slavery or human trafficking in any part of the consultancy or its supply chain. I expect the same standard from my suppliers, partners, and associates. Where modern slavery concerns arise — whether through whistleblowing, audit, or external information — they will be investigated and acted upon.
Where the consultancy engages associate consultants or subcontractors, due diligence is conducted as part of the engagement process. This includes verification of right-to-work documentation, confirmation that the engagement is genuinely contractual, and confirmation that the engagement complies with employment status rules.
As a sole practitioner consultancy, formal training on modern slavery is not currently provided. As the consultancy grows and engages associate consultants, modern slavery awareness will be incorporated into the onboarding process for any associate engagement.
If you have a concern relating to modern slavery in connection with Varnham Consulting Ltd or its supply chain, please raise it through the intake form on the contact page, selecting option 13 ("Something else") and indicating "modern slavery concern" in the optional notes field. Concerns are taken seriously and investigated.
This statement is reviewed annually and at any point where the consultancy's operations or supply chain change materially. The next scheduled review is April 2027.
Signed,
Matthew Varnham
Founder & Principal
Date of statement: 27 April 2026