Policy
Anti-slavery, by principle.
Modern slavery and human trafficking have no place in our business or our supply chain. This policy sets out what we do about it, proportionate to the size and nature of our operations.
- Policy Owner
- Craig Hartzel, Founder
- Applies To
- All staff, contractors, partners
- Next Review
- May 2027
Section
01
Purpose & Scope
Modern slavery and human trafficking have no place in our business or our supply chain. This policy sets out the position of The Hartz Company Limited, trading as Hartz AI, on modern slavery, forced labour, servitude, and human trafficking, and the steps we take to guard against them.
It applies to everyone who works for or on behalf of Hartz AI, including employees, directors, contractors, freelance associates, and delivery partners, regardless of their location.
Hartz AI is a small UK consultancy and falls below the statutory turnover threshold for a slavery and human trafficking statement under section 54 of the Modern Slavery Act 2015. We publish this policy voluntarily because we believe the standards behind that legislation should apply to organisations of any size, and because our clients in regulated and public-sector contexts expect it.
Section
02
Our Business
Hartz AI provides artificial intelligence training, consultancy, governance advice, and bespoke implementation services to UK organisations. We operate primarily from the United Kingdom and engage a small number of UK-based associates and overseas software suppliers.
Our risk of encountering modern slavery in our direct operations is low. The areas where risk is more material, and where this policy is focused, are:
- Cleaning, facilities, and event services we purchase from third parties.
- Hardware, merchandise, and printed materials sourced through resellers.
- Overseas software development, data labelling, and content moderation suppliers in our extended supply chain.
- Subcontracted associates and delivery partners who deliver work in our name.
Section
03
Our Workforce
Everyone who works for Hartz AI has the right to be treated with dignity and to work in conditions that meet UK employment law. We commit to:
- Paying at or above the Real Living Wage for all roles, including freelance and short-term engagements.
- Verifying the right to work in the United Kingdom for all employees and contractors before they begin work.
- Issuing written terms of engagement to every contractor, with clear scope, payment terms, and notice arrangements.
- Refusing to hold passports, identity documents, or wages as a condition of employment under any circumstances.
- Refusing to charge any worker, directly or indirectly, a fee in exchange for being hired.
All staff are made aware of this policy on joining and are expected to raise any concern about working conditions, their own or anyone else's, through the route set out in section 06.
Section
04
Our Supply Chain
We take a proportionate, risk-based approach to supplier due diligence. The depth of checks scales with the size of the engagement and the inherent risk of the category.
For new suppliers in higher-risk categories we will, before placing an order:
- Confirm the supplier has its own modern slavery policy or, for very small suppliers, a written commitment in line with this one.
- Ask whether the supplier subcontracts any part of the work, and to whom.
- Decline to engage suppliers who cannot give satisfactory answers, or whose published statements suggest a serious gap.
For existing suppliers we will:
- Revisit the questions above at contract renewal, or sooner if our risk picture changes.
- Investigate promptly and in good faith if a credible concern is raised about a supplier or one of its subcontractors.
- Terminate the relationship where we identify modern slavery and the supplier is unwilling or unable to address it.
We expect our suppliers to apply the same standards to their own suppliers, and we reserve the right to ask for evidence that they have done so.
Section
05
Responsibilities
Final accountability for this policy sits with the founder, Craig Hartzel, who acts as the senior responsible owner.
- Founder (Craig Hartzel): Approves this policy, reviews it annually, and makes the decision to disengage from suppliers where required.
- All staff and contractors: Read this policy, follow it, and raise concerns promptly.
- Anyone signing a new supplier contract on behalf of Hartz AI: Carries out the proportionate due diligence set out in section 04 before commitment.
A breach of this policy by an employee or contractor is treated as a serious matter and may lead to termination of engagement. A breach by a supplier may lead to termination of contract.
Section
06
Raising Concerns
If you suspect modern slavery or human trafficking in any part of our business or supply chain, raise it. You do not need proof, and you will not face retaliation for raising a concern in good faith.
- Email craig@hartzai.com with as much detail as you can share.
- If the concern relates to the founder, or you would prefer to raise it externally, contact the Modern Slavery and Exploitation Helpline on 08000 121 700.
- If you believe someone is in immediate danger, contact the police on 999.
We will acknowledge any concern raised with us within five working days, investigate proportionately, and keep the person who raised it informed of progress to the extent that confidentiality allows.
Section
07
Review & Continuous Improvement
This policy is reviewed at least once a year, and sooner if our business or risk picture changes materially. The next scheduled review is May 2027.
Each review considers:
- Any concerns raised in the previous twelve months and how they were handled.
- Changes to our supplier base or the categories we buy in.
- Changes in UK law, guidance from the Home Office, or sector best practice.
- Feedback from clients whose own due diligence has surfaced useful improvements.
We will publish material changes on this page and update the version and review date in the policy footer below.
- Issued By
The Hartz Company Limited
trading as Hartz AI
Wohl Enterprise Hub, 2b Redbourne Avenue
London N3 2BS, United Kingdom
- Version
- 1.0, May 2026
Questions about this policy? We're happy to talk it through.
If you are a client carrying out procurement due diligence, or a supplier checking our expectations, get in touch.
Contact Hartz AI