Modern Slavery Statement
Modern Slavery Statement
Statement under the UK Modern Slavery Act for the Financial Year Ending 31 December 2025 (the “Statement”)
This Statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”) and constitutes Atlas NextWave Group’s modern slavery and human trafficking statement for the financial year ending 31 December 2025.
This Statement is made on behalf of Atlas Professionals B.V. and the following United Kingdom entities within the Atlas NextWave Group that fall within the scope of section 54 of the Modern Slavery Act 2015:
- Atlas Professionals UK Limited;
- Atlas Professionals Services Limited;
- NextWave Partners EMEA Ltd; and
- Atlas Professionals International Limited.
These entities are collectively referred to in this Statement as “Atlas NextWave Group”, “We”, “Our”, or “the Group.”
The Group operates through a network of subsidiaries across Europe, Asia-Pacific, and the Americas, delivering workforce and marine personnel solutions in both onshore and offshore environments. In the United Kingdom, services include recruitment, agency worker supply, contractor management, and intermediary payroll arrangements.
Our supply chain primarily consists of recruitment partners, umbrella companies, employers of record, marine crewing agents, payroll providers, immigration advisors, and professional services firms.
Our Business and Vision
Atlas NextWave Group is a global provider of full-service staffing, workforce solutions, and marine personnel services across the clean-tech, energy, infrastructure, and marine sectors.
Our vision is to help shape the sustainable future of the clean-tech, energy, infrastructure, and marine markets by delivering creative people solutions and supporting our customers, colleagues, and candidates in making a meaningful impact on the journey to net zero by 2050.
As a workforce solutions provider operating in multiple jurisdictions, we recognise our heightened responsibility to ensure ethical recruitment, fair employment practices, and transparent supply chains.
Our Commitment to Preventing Modern Slavery
Atlas NextWave Group maintains a zero-tolerance approach to modern slavery, forced labour, debt bondage, human trafficking, and child labour.
We are committed to:
- Upholding internationally recognised human rights standards, including ILO conventions;
- Ensuring recruitment is free from worker-paid fees;
- Promoting contract transparency and fair remuneration;
- Respecting freedom of association and collective bargaining;
- Providing accessible grievance and whistleblowing mechanisms;
- Acting promptly where concerns arise.
We expect the same standards from all suppliers, subcontractors, recruitment partners, and business counterparties.
Our approach is informed by the UN Guiding Principles on Business and Human Rights.
Governance and Policies
During the financial year 2025, we maintained and further enhanced our governance framework relating to ethical business conduct, responsible recruitment practices, and labour standards.
We have established policies, procedures, and internal controls designed to promote compliance with applicable laws, uphold human rights, and support ethical business practices across our operations and supply chains.
These measures apply to employees, contractors, workers, and, where appropriate, suppliers and business partners. They are intended to prevent forced labour, child labour, human trafficking, exploitative recruitment practices, and any form of coercion, discrimination, or unlawful treatment.
Oversight of modern slavery risks is supported by senior management and the Board, with input from relevant corporate functions and subject matter specialists. Modern slavery considerations form part of the Group’s broader compliance, risk management, and governance framework.
The Board and senior management receive periodic updates regarding modern slavery risks, supply chain due diligence activities, and any significant compliance matters. Day-to-day implementation and monitoring are supported through the Group’s operational, legal, compliance, and management processes.
Monitoring of UK Employment Rights Reform and Umbrella Company Regulatory Developments
During the financial year 2025, the Group monitored legislative developments relating to the
Employment Rights Act 2025, which received Royal Assent in December 2025, together with associated policy proposals and regulatory consultations affecting agency workers, intermediaries, and umbrella company arrangements in the United Kingdom.
As implementation of many provisions will occur through subsequent secondary legislation and regulatory guidance, the Group undertook preparatory compliance reviews to ensure readiness for future regulatory changes affecting labour supply chains.
As a workforce solutions provider, we recognise that opaque labour supply chains, improper worker classification, unlawful deductions, or non-transparent umbrella company practices may increase the risk of worker exploitation and financial coercion, which are recognised risk indicators of modern slavery.
Accordingly, during 2025 we:
- Continued to review and strengthen our recruitment, onboarding, and workforce management processes;
- Applied risk-based due diligence measures in relation to suppliers, labour providers, and other business partners;
- Maintained controls designed to promote transparency, fair treatment, and compliance with applicable employment and labour standards;
- Reviewed contractual arrangements and commercial relationships to support responsible business practices and worker protections;
- Reinforced our commitment to ethical recruitment and the prevention of practices that could contribute to worker vulnerability or exploitation; and
- Continued to monitor legal, regulatory, and industry developments relevant to labour standards and human rights risks.
We recognise that effective governance, transparency, and responsible business practices play an important role in reducing the risk of modern slavery and labour exploitation. The Group will continue to review and enhance its policies, procedures, and due diligence processes as part of its ongoing commitment to preventing modern slavery within its operations and supply chains.
Risk Assessment
As a global workforce solutions provider, the Group recognises that modern slavery risks may arise particularly in:
- Labour-sourcing and recruitment arrangements
- Marine and offshore deployments
- Use of third-party employers of record
- Operations in higher-risk jurisdictions
- Subcontracted workforce arrangements
We conduct ongoing risk assessments across both:
- Our direct operations; and
- Our external supply chains.
Based on our 2025 assessment, we consider the risk within our direct corporate operations to be low. However, we recognise that supply chain risks may increase in certain labour-sourcing and offshore environments, particularly where regulatory enforcement may be weaker.
We therefore apply enhanced due diligence in higher-risk scenarios.
Within the UK market, we recognise that complex labour supply chains including umbrella company arrangements and intermediary payroll models may present heightened risks where transparency, worker classification, or statutory entitlements are not clearly managed. The Group therefore considers regulatory developments under the Employment Rights Act 2025 and emerging umbrella company legislation as relevant to our ongoing modern slavery risk assessment and compliance programme.
Where we operate under client contracts that involve subcontracting or multi-tier labour supply chains, we seek contractual alignment and flow-down of anti-modern slavery obligations.
Due Diligence and Supply Chain Monitoring
We operate a risk-based due diligence framework embedded within our Integrated Management System and ISO certification processes.
Depending on risk profile, due diligence measures include:
- Detailed supplier questionnaires covering recruitment methods, subcontracting, and labour practices;
- Verification of corporate structure, licensing, and regulatory compliance;
- Review of human rights and anti-trafficking policies;
- Mandatory contractual provisions prohibiting forced and child labour;
- Zero-fee recruitment confirmations;
- Transparency requirements regarding employment terms and remuneration;
- Escalation and termination rights for material breaches;
- Periodic desk-based or in-person audits for higher-risk jurisdictions.
- Specific due diligence of umbrella companies and labour intermediaries operating within the United Kingdom, including verification of worker status compliance, pay transparency, lawful deductions, and tax compliance, together with assessment of alignment with emerging regulatory reforms relating to umbrella company oversight and labour supply chain transparency.
In marine and offshore contexts, we additionally consider compliance with Maritime Labour Convention (MLC) standards where applicable.
In marine and offshore operations, the Group recognises that seafarers and offshore personnel may face heightened risks of labour exploitation due to the remote nature of operations, complex subcontracting arrangements, and cross-border recruitment practices. Accordingly, we place particular emphasis on ensuring transparency of employment terms, compliance with Maritime Labour Convention (MLC) requirements where applicable, and verification that recruitment practices do not involve worker-paid fees, debt arrangements, or coercive conditions. Where relevant, we seek contractual commitments from crewing agents, subcontractors, and recruitment partners confirming adherence to international labour standards and applicable maritime regulations.
We also seek to ensure that seafarers and offshore personnel receive clear written employment terms prior to deployment and have access to grievance mechanisms that allow concerns to be raised without fear of retaliation.
During 2025, we maintained adherence to external regulatory frameworks and successfully completed audits by authorities including:
- The Employment Agency Standards Inspectorate (United Kingdom); and
- The Stichting Normering Arbeid (SNA) in the Netherlands.
No material instances of modern slavery were identified within our operations.
Effectiveness of Our Approach
Atlas NextWave Group evaluates the effectiveness of its modern slavery prevention framework through ongoing governance, risk assessment, due diligence activities, internal reporting, and management oversight.
During the financial year ending 31 December 2025, no material instances of modern slavery, forced labour, human trafficking, or child labour were identified within our direct operations.
Where concerns are raised, they are reviewed and investigated in accordance with our internal compliance procedures and, where appropriate, escalated to senior management. Corrective actions may include remediation measures, supplier engagement, contractual enforcement, termination of business relationships, or disciplinary action.
We maintain a strict non-retaliation approach and encourage employees, contractors, workers, suppliers, and other stakeholders to raise concerns through our whistleblowing and grievance reporting channels.
The Group remains committed to continually reviewing and strengthening its policies, procedures, and governance arrangements to identify and mitigate modern slavery risks across its operations and supply chains.
Continuous Improvement
We recognise that modern slavery risks evolve, particularly within global labour markets and offshore supply chains.
In 2026, we will continue to:
- Enhance supplier risk-mapping tools;
- Strengthen contractual flow-down obligations;
- Expand audit coverage in higher-risk regions;
- Refine training for frontline recruitment teams;
- Continue to review and enhance our modern slavery governance, due diligence, and supply chain oversight processes in line with evolving legal, regulatory, and industry expectations.
Declaration
This Statement was approved by the Board of Directors of Atlas Professionals B.V. on behalf of the UK entities listed above.
Neil Tregarthen
CEO, Atlas NextWave