Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that L25 Limited (trading as CasePattern) has taken and is continuing to take to ensure that modern slavery and human trafficking are not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking, and forced labour. L25 Limited has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

Our Business

L25 Limited, trading as CasePattern, provides an analytics platform that uncovers patterns and inconsistencies in Financial Ombudsman Service (FOS) decisions. Based in Telford, United Kingdom, we operate primarily in the legal technology sector, delivering data analytics services to legal professionals, claims management companies, and financial institutions throughout the UK.

Our business model is predominantly digital, with a focus on software development and data analysis. As such, our supply chain is relatively limited and primarily comprises:

• Software development services

• Cloud hosting and data infrastructure providers

• Professional services (consulting)

• Office-related goods and services

Our Policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

Anti-Slavery and Human Trafficking Policy

Our anti-slavery policy outlines our zero-tolerance approach to modern slavery and sets out our expectations for all those who work for us or on our behalf. The policy explains how to identify and report concerns regarding modern slavery and the protections available for whistleblowers.

Whistleblowing Policy

Our whistleblowing policy ensures all employees know they can raise concerns about how colleagues are being treated, or about practices within our business or supply chain, without fear of reprisal. The policy encourages openness and will support anyone who raises genuine concerns in good faith.

Recruitment Policy

We operate a robust recruitment policy that includes conducting eligibility checks for the right to work in the UK for all employees and ensuring that all staff are paid at least the National Living Wage. We conduct appropriate background checks and verify the agencies we use for the provision of temporary or agency staff.

Supplier Code of Conduct

Our supplier code of conduct includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.

Due Diligence Processes

As part of our initiative to identify and mitigate risk, we have in place systems to:

• Identify and assess potential risk areas in our supply chains

• Mitigate the risk of slavery and human trafficking occurring in our supply chains

• Monitor potential risk areas in our supply chains

• Protect whistleblowers

We have undertaken the following due diligence processes:

1. Supplier Vetting: We conduct risk assessments on all new suppliers and regularly review existing suppliers. Higher-risk suppliers are subject to enhanced due diligence.

2. Contractual Controls: Our contracts with suppliers include specific prohibitions against the use of forced, compulsory or trafficked labour.

3. Supplier Questionnaires: We require key suppliers to complete questionnaires about their labour practices and those of their suppliers.

4. Auditing and Verification: For higher-risk suppliers, we may conduct audits or require third-party verification of their practices.

Risk Assessment

Given the nature of our business as a technology company providing data analytics services within the UK, and the fact that we do not have complex supply chains, use of unskilled labour, or manufacture goods, we believe the risk of modern slavery in our business and supply chains is low.

However, we recognise that no supply chain can be considered entirely free from risk. We have identified the following areas that may present a higher risk:

• Third-party software development services

• Cleaning and facilities management services

• IT hardware suppliers (due to manufacturing processes that may occur in higher-risk regions)

We have implemented enhanced due diligence procedures for suppliers in these higher-risk categories.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and supply chains, we provide training to our staff. This training covers:

• Our business's purchasing practices

• How to identify the signs of slavery and human trafficking

• What initial steps should be taken if slavery or human trafficking is suspected

• How to escalate potential slavery or human trafficking issues to the relevant parties within our organisation

• What external help is available (e.g., the Modern Slavery Helpline)

Performance Indicators

We use the following key performance indicators (KPIs) to measure our effectiveness in ensuring that slavery and human trafficking are not taking place in our business or supply chains:

• Completion rates of staff training on modern slavery

• Number of reports received from employees, suppliers, or the public regarding modern slavery concerns

• Actions taken in response to reports

• Supplier due diligence assessments completed

Looking Ahead

We will continue to enhance our procedures to help us identify, prevent and mitigate any risks of modern slavery or human trafficking in relation to new and existing suppliers. We will also continue to train our staff on the importance of tackling modern slavery and how to spot potential signs of exploitation.

Board Approval

This statement has been approved by the Board of Directors of L25 Limited, who will review and update it annually.

Signed:

Luke Roberts

Name: Luke Roberts
Position: Director, L25 Limited
Date: April 2025

Contact Information:
L25 Limited (trading as CasePattern)
St James House
Hollinswood Road
Telford
TF2 9TZ

Email: legal@casepattern.co.uk