Sylfaen Advisory is committed to the Welsh Government's Code of Practice: Ethical Employment in Supply Chains.
Sylfaen Advisory Limited is a sole-director consultancy, pre-revenue as of July 2026, working toward first client engagements from around December 2026. This policy sets out how we are adopting the Welsh Government's Code of Practice: Ethical Employment in Supply Chains, and the 12 commitments it sets out.
As a small organisation with no employees other than the director, action taken against each commitment is proportionate to our size, structure, and the level of risk of labour exploitation in our own operations and supply chain — in line with the Code's own guidance for small organisations. Several commitments (for example, those concerning managing subcontracted workforces at scale) will become more substantial as we grow and bring on associates; this document will be reviewed and expanded as that happens.
This policy also fulfils Commitment 1 of the Code, which requires a written policy on ethical employment, communicated throughout the organisation and reviewed annually.
Mark Biscoe, Founder & Director, is appointed as Sylfaen Advisory's Anti-Slavery and Ethical Employment Champion, responsible for this policy, for monitoring its effectiveness, and for the annual review.
This document is our written policy on ethical employment, covering our own organisation and our supply chain.
It will be communicated to anyone joining Sylfaen as an employee, associate, or subcontractor, and reviewed annually by the Anti-Slavery and Ethical Employment Champion.
An Anti-Slavery and Ethical Employment Champion has been appointed (Section 2).
Anyone working with or for Sylfaen — employee, associate, or supplier — can raise a concern about suspected unlawful or unethical employment practice, in our organisation or our supply chain, directly with Mark Biscoe (mark@sylfaenadvisory.co.uk), without fear of detriment.
External parties (e.g. a supplier's workers) can raise concerns via the same address.
Concerns will be looked into promptly and, where they concern criminal activity, reported to the appropriate authority.
This arrangement will be formalised into a standalone policy once Sylfaen takes on its first associate or employee, and reviewed annually thereafter.
Mark Biscoe has completed relevant induction reading on modern slavery and ethical employment practice as part of adopting this Code.
Any future associate or employee involved in buying, procurement, or recruitment will complete equivalent training before taking on that work, and a record will be kept.
Not yet applicable in practice — Sylfaen has no other staff or procurement activity as at July 2026.
Our ethical employment policy will be included in any procurement documentation we issue.
Any future tender or subcontract process will include questions on ethical employment, assessed as part of supplier selection.
Elements of the Code will be incorporated into contract conditions where appropriate.
Any abnormally low quote received will be queried directly with the bidder as to the impact on their workers.
We will not apply undue cost or time pressure to any supplier where this is likely to result in unethical treatment of their workers.
We will pay suppliers within 30 days of receipt of a valid invoice.
We will encourage suppliers and subcontractors we engage to sign up to this Code of Practice, to help ensure ethical employment practices are carried out through the supply chain.
We will review our supplier expenditure periodically and assess risk of modern slavery or unethical employment practice, in the UK and overseas.
Any supplier identified as high risk will be investigated, engaging directly with workers where possible.
We will work with any such supplier to rectify issues identified, and monitor progress.
Proportionate to Sylfaen's current scale: our current spend is limited to standard UK/EU professional software and services (e.g. cloud hosting, accountancy). This will be formalised as a standing agenda item once we manage a live subcontractor or associate base.
Sylfaen will not engage workers as false self-employed, or use umbrella schemes or zero hours contracts, to avoid tax, National Insurance, or minimum wage obligations, to disadvantage workers on pay, rights, job security or career opportunities, or to avoid health and safety responsibilities.
Associates are engaged on a deliverables basis (paid for defined outputs, not simply hours worked), consistent with IR35 good practice and this commitment.
Sylfaen does not use blacklists or prohibited lists, will not contract with any supplier known to have used one and failed to put matters right, and will expect suppliers to allow Trade Union representatives to access members and contracted workers.
Workers are free to join a Trade Union or raise concerns without risk of discrimination.
Sylfaen will consider paying at least the Living Wage Foundation's Living Wage to all UK staff and associates, and will consider becoming an accredited Living Wage Employer as the business grows.
We will encourage suppliers to pay a fair wage to overseas staff and at least the minimum wage to UK staff.
Sylfaen will produce an annual written statement outlining steps taken and planned to ensure slavery and human trafficking are not taking place in our organisation or supply chain, signed off by the Director.
The statement will be published on our website, or provided to any requester within 30 days.
As Sylfaen's turnover is well below the £36 million Modern Slavery Act 2015 Section 54 threshold, this statement is voluntary but will be produced in the same spirit.
First annual statement due to be produced alongside the July 2027 policy review.
Not applicable. This commitment applies to public sector bodies transferring staff as part of an outsourced service; Sylfaen is a private consultancy and does not undertake this type of arrangement.
This policy is owned by Mark Biscoe, Founder & Director, and will be reviewed annually — next review due 29 July 2027 — or sooner if Sylfaen takes on its first employee, associate, or subcontractor.
