| Covers | The period up to 23 October 2026 |
|---|---|
| Basis | Welsh Government Code of Practice: Ethical Employment in Supply Chains, Commitment 11; Modern Slavery Act 2015 (voluntary statement) |
| Approved by | Dan Crandon, Director of Operations |
| Signed by | Stuart Arthur, Chief Executive Officer |
| Published | joinscout.org |
Scout AI Group does not tolerate modern slavery, human trafficking or unethical employment practice in its business or supply chains. This statement sets out what Scout has done, the risks it has found, and what it will do next.
This is Scout's first statement. It covers the period up to 23 October 2026, including Scout's sign-up to the Welsh Government Code of Practice: Ethical Employment in Supply Chains in October 2026. Scout's turnover is below the £36 million threshold in section 54 of the Modern Slavery Act 2015, so this statement is voluntary. It meets Commitment 11 of the Code, Policy 38 section 7 and Policy 43 section 12. The next statement will follow Scout's first financial year end.
1. Our structure, business and supply chains
Scout AI Group Ltd is a UK holding company. This statement covers it and the companies that have adopted its policies:
| Company | What it does |
|---|---|
| Scout AI Group Ltd | Holding company |
| Scout AI Labs Ltd | Builds and fine-tunes AI models; owns the group's intellectual property |
| Scout AI Operations Ltd | AI consulting, implementation and delivery |
| Scout AI Talent Ltd | Recruitment and staffing |
| Scout Academy Ltd | Training. Joining the group, and has adopted the group's policies |
Scout works mainly with public sector bodies, social housing providers and EU clients. Its people work remotely, from home.
Scout's main supply chains are:
- cloud, software and AI model providers
- IT hardware and devices
- associates and subcontractors who help deliver client work
- recruitment of workers by Scout AI Talent Ltd, which recruits directly and does not use umbrella companies
2. Our policies
| Policy | What it covers |
|---|---|
| Policy 43 Ethical Employment and Modern Slavery | How Scout meets the Welsh Government Code, including employment status, supplier treatment, blacklisting, the Living Wage and training |
| Policy 38 Modern Slavery and Human Trafficking | Supply chain due diligence and recruitment safeguards |
| Policy 20 Whistleblowing | How anyone, inside or outside Scout, can raise a concern, and the duty on staff to report criminal activity |
| Policy 26 Associates and Contractors | How Scout engages associates and contractors |
| Policy 41 Scout AI Talent Agency Compliance | The rules Scout AI Talent Ltd follows as a recruiter |
3. Risks and due diligence
| Area | Risk | What Scout does |
|---|---|---|
| Associates and contractors | False self-employment where an individual works for Scout alone, long term, under Scout's control | Assess the status of every engagement and put right any that is wrong (section 5) |
| IT hardware and devices | Forced labour in manufacturing and mineral sourcing | Buy from established suppliers that publish a modern slavery statement |
| Recruitment through Scout AI Talent Ltd | Fees charged to workers, debt bondage, retained documents | No fees to work-seekers; right to work checks; identity documents not retained; wages paid into the worker's own account; direct recruitment only |
| Cloud, software and AI model providers | Low | Use providers with published modern slavery statements |
Scout's highest risk is in its own use of self-employed associates and contractors. Some have worked for Scout alone over long periods, which can amount to false self-employment. Scout is assessing every engagement, and the action is set out in section 5.
4. Steps taken in 2026
- Signed up to the Welsh Government Code of Practice: Ethical Employment in Supply Chains in October 2026.
- Appointed the Director of Operations as Anti-Slavery and Ethical Employment Champion on 21 October 2026, with the Operations and Delivery Manager as alternate.
- Approved Policy 43 Ethical Employment and Modern Slavery and Policy 20 Whistleblowing Version 2 on 21 October 2026.
- Opened a confidential reporting address, available to people outside Scout and seen only by the Champion and the alternate.
- Briefed all staff, contractors and associates on both policies.
- Confirmed that Scout pays valid supplier invoices within 30 days.
- Confirmed that Scout AI Talent Ltd recruits directly and uses no umbrella companies.
5. Plans for the next year
| Action | By |
|---|---|
| Assess the employment status of every existing associate and contractor engagement, and restructure or offer employment where the status is wrong | 23 January 2027 |
| Train everyone who buys services, recruits or deploys workers, including every Scout AI Talent Ltd consultant, using the Welsh Government e-learning | 31 March 2027 |
| Ask existing subcontractors and associate companies to sign up to the Code | 31 March 2027 |
| Complete the first spend review and supplier risk register | 31 March 2027 |
| Decide whether to pay the Living Wage Foundation's Real Living Wage and seek accreditation, and record the reasons | When the new rate is announced |
| Review Policies 20 and 43 | October 2027 |
6. How we will measure progress
The next statement will report against these measures, including the number of concerns raised and how they were resolved.
| Measure | Target |
|---|---|
| Associate and contractor engagements with a recorded status assessment | 100% |
| People in buying and recruitment roles trained in the last 12 months | 100% |
| Valid supplier invoices paid within 30 days | 100% |
| High-risk suppliers with an agreed action plan | 100% |
7. Approval
This statement was approved by the Director of Operations and is signed by the Chief Executive Officer for Scout AI Group Ltd and the companies listed in section 1. It is published on joinscout.org, and a copy is given to anyone who asks within 30 days.
Raising a concern
If you have a concern about modern slavery, human trafficking or unethical employment connected to Scout, its suppliers or partners, please contact us. You can also ask us for a copy of this statement.
Questions about this statement?
If anything here is unclear, or you need this document in another format, get in touch and we’ll help.