Last updated: May 2026 | Financial year ending: 30 April 2027
| Voluntary statement The statutory duty to publish an annual modern slavery and human trafficking statement under section 54(1) of the Modern Slavery Act 2015 applies to commercial organisations with a turnover of £36 million or more. Sparkline Advisory Ltd does not meet that threshold and is not legally required to publish this statement. We publish it voluntarily, in the spirit of the Act and in recognition of our responsibilities as a supplier to organisations in the higher and further education sectors, where transparency in supply chains is increasingly expected of all suppliers regardless of size. |
Introduction
Modern slavery is a crime and a serious violation of fundamental human rights. It takes many forms, including slavery, servitude, forced and compulsory labour, and human trafficking – all of which involve the exploitation of individuals who are deprived of their liberty for personal or commercial gain.
Sparkline Advisory Ltd has zero tolerance for modern slavery and human trafficking in any form. This statement sets out our position, the nature of our business and supply chains, and the steps we take to identify and prevent modern slavery in our operations.
About our organisation
Sparkline Advisory Ltd (company number 17164009) is a data and technology consultancy incorporated in England and Wales, led by Martha Horler as sole director. We provide professional services to organisations primarily in the higher education (HE) and further education (FE) sectors across the UK.
Our services include:
- Data governance consultancy and framework development.
- Data protection advisory services, including UK GDPR compliance and DPO-level support.
- Responsible AI policy development and governance advisory.
- HESA and OfS data return support and quality assurance.
- Data strategy, analytics, and capability development.
- Training, workshops, and online learning for data and digital professionals.
Our registered office is at Piccadilly Business Centre, Unit C, Aldow Enterprise Park, Blackett Street, Manchester, M12 6AE. We operate exclusively within the United Kingdom.
Our structure and workforce
Sparkline Advisory Ltd is a small company with a single director and no employees. Occasional project-specific work may be delivered with the support of freelance contractors or collaborators, engaged on a self-employed basis for specific engagements.
All contractors and collaborators engaged by us are required to operate in compliance with applicable UK law, including employment and anti-slavery legislation. We do not engage contractors through intermediaries or labour supply chains that might obscure the nature of working arrangements.
Our supply chains
As a professional services consultancy, our supply chains are minimal and low-risk. We do not manufacture goods, operate physical premises, or engage in industries typically associated with elevated modern slavery risk.
Our principal third-party suppliers are:
- Software and platform providers – including website hosting (WP Engine), payment processing (Stripe), email marketing (MailerLite), and business software (FreeAgent, Microsoft 365). These are established, reputable providers subject to UK and international regulatory frameworks.
- Professional services – including accountancy and legal advisers, all of whom are UK-based regulated professionals.
- Freelance contractors and collaborators – engaged on a project-specific basis for specific deliverables, as described above.
We do not use overseas manufacturing, physical supply chains, or labour supply agencies. The nature of our business means our exposure to modern slavery risk in our supply chain is assessed as low. We nonetheless remain vigilant and would act promptly if concerns arose.
Risk assessment
We have considered our exposure to the risk of modern slavery across our operations and supply chains. Given the nature of our business – a small UK-based professional services consultancy with no physical supply chain, no employees, and suppliers who are predominantly established UK-regulated businesses – we assess our overall risk level as low.
The areas we consider in our risk assessment are:
- Workforce – no employees; contractors engaged on self-employed basis with transparent working arrangements.
- Supply chain – limited to software subscriptions, professional services, and occasional freelance support, all within the UK.
- Client base – primarily public sector and regulated education institutions, themselves subject to their own modern slavery obligations.
We will repeat this risk assessment annually and update it if our business model, workforce, or supply chains change materially.
Due diligence
We take the following steps to identify and address modern slavery risk in our operations:
- We engage contractors and collaborators only on clear, written terms that reflect genuine self-employment and fair working arrangements.
- We use established, reputable software and service providers, and review their published modern slavery statements and ethical commitments where available.
- We prefer UK-based suppliers where practicable, as these are subject to UK employment law and anti-slavery legislation.
- We remain alert to indicators of modern slavery or labour exploitation in any business relationship and would cease engagement with any supplier or collaborator where such concerns arose.
- We do not knowingly support or engage with any business involved in modern slavery or human trafficking.
Our commitment
Sparkline Advisory Ltd is committed to acting ethically, with integrity, and in accordance with the law in all its business dealings and relationships. We expect the same standards from all those we work with.
We recognise that modern slavery and human trafficking are issues that extend beyond high-risk industries, and that all organisations have a responsibility to be aware of and act on the risks in their own context. We take that responsibility seriously, regardless of the scale of our operations.
If we become aware of any instance of modern slavery or human trafficking in connection with our business or supply chains, we will take immediate steps to address it, including ceasing any relevant business relationship and, where appropriate, reporting concerns to the relevant authorities including the National Crime Agency’s Modern Slavery Helpline (0800 0121 700).
Training and awareness
As a small single-director company, formal staff training programmes are not applicable at present. Martha Horler, as director, maintains awareness of modern slavery issues and the obligations that apply to businesses operating in our sectors.
Any contractors or collaborators engaged by Sparkline Advisory Ltd are made aware of our ethical standards and our zero-tolerance approach to modern slavery as part of our engagement process. As the business grows, we will review whether additional training or awareness measures are appropriate.
Reporting concerns
Anyone who has concerns about modern slavery or human trafficking in connection with our business is encouraged to raise them with us directly at [email protected]
Concerns can also be reported to the National Crime Agency’s Modern Slavery Helpline on 0800 0121 700 (24 hours, 7 days a week) or at modernslaveryhelpline.org. In an emergency, contact the police on 999.
Review
This statement will be reviewed annually and updated to reflect any changes to our business, supply chains, or relevant legislation and guidance. The review date is recorded at the top of this document.