This statement is published by Blankstate (trading name of Traceflow Ltd, a company incorporated in England and Wales). It is published on a voluntary basis: Blankstate (Traceflow Ltd) does not currently meet the £36m turnover threshold that triggers the statutory reporting obligation under section 54 of the UK Modern Slavery Act 2015. We publish it anyway because we believe transparency is the right default — and because we want our customers, partners, and people to know where we stand.
1. Our zero-tolerance position
Blankstate has a zero-tolerance approach to modern slavery, servitude, forced and compulsory labour, and human trafficking — both within our own operations and within our supply chain. We expect our suppliers, sub-processors, and partners to operate to the same standard, and we take steps to satisfy ourselves that they do.
2. About Blankstate
Blankstate (Traceflow Ltd) is a UK-domiciled software company. We build infrastructure that measures and audits AI systems. Our principal product is a software-as-a-service platform operated from Google Cloud Platform europe-west2 (London, United Kingdom).
- Predominantly remote workforce of approximately a dozen people across the UK and India.
- Direct supply chain consisting principally of cloud infrastructure (Google Cloud), source-control (GitHub Enterprise), endpoint security (Bitdefender GravityZone), productivity tools (Google Workspace), payment processing for our own billing (Stripe), and professional services (accountants, legal counsel).
- We do not operate manufacturing, mining, agriculture, construction, fisheries, hospitality, or any other sector traditionally associated with elevated modern-slavery risk.
We assess our own modern-slavery risk profile, therefore, as low — but “low” is not “zero”, and this statement sets out what we do to keep it that way and to address the residual risk through our supply chain.
3. Our people
- All Blankstate personnel are engaged under contracts that comply with the employment law of their working jurisdiction.
- Identity and right-to-work checks are performed before the first day of work in accordance with UK Home Office requirements (or equivalent local requirements), per
BKS-HRS-001§3. - Personnel are paid at or above the legal minimum in their working jurisdiction; we use independent salary benchmarks to inform pay decisions.
- We do not retain identity documents, personnel passports, or other restrictions on freedom of movement.
- Personnel have access to a confidential Speak-Up channel for concerns, including suspected exploitation in our operations or supply chain (
BKS-WHB-001).
4. Our supply chain
4.1 Direct suppliers
Our material direct suppliers are listed in BKS-SUB-001 (Sub-Processor List) and in our wider third-party register. They are predominantly large, well-established global technology providers (Google, Microsoft / GitHub, Stripe, Bitdefender), each of whom publishes their own Modern Slavery Statement under the UK Modern Slavery Act 2015 or equivalent regimes elsewhere. We rely on these public statements as a first line of supply-chain assurance.
4.2 Due diligence
New suppliers are onboarded under BKS-TPR-001 (Third-Party Risk Management Procedure). For each material supplier, due diligence includes consideration of modern-slavery risk proportionate to the sector and jurisdiction:
- Confirmation of published modern-slavery commitments or statements where available.
- Sanctions / adverse-media screening (per
BKS-SAN-001). - Sector-based risk consideration (we apply heightened scrutiny to any new supplier in a higher-risk sector, including any hardware, logistics, facilities, or human-services engagement).
4.3 Contractual safeguards
Material supplier contracts include — or will include on next renewal — representations of compliance with applicable modern-slavery, anti-bribery, and labour law, and reservation of audit / termination rights for material breach.
4.4 Sub-contracting
Suppliers may not sub-contract material parts of the engagement without our consent. Where they do, equivalent obligations apply through their contracts with their sub-contractors.
5. Training and awareness
- Modern-slavery awareness is covered in the onboarding ethics module and the annual refresher (
BKS-COC-001). - Personnel in procurement, partnerships, and customer-facing roles receive role-specific training on identifying and escalating suspected modern-slavery risk in counterparties.
- This statement is referenced in our staff handbook and on the public Trust Center.
6. Reporting and escalation
Personnel, suppliers, customers, and any other interested party can raise concerns about modern slavery in Blankstate’s operations or supply chain through:
- Email:
speakup@blankstate.ai(confidential, accepts anonymous reports). - The Owner or Blankstate’s executive ownership directly.
- External authorities: the UK Modern Slavery & Exploitation Helpline (08000 121 700) or the UK Modern Slavery Helpline online portal.
Retaliation against anyone reporting in good faith is prohibited (BKS-WHB-001 §5).
7. Effectiveness
Given the size and risk profile of Blankstate, we measure the effectiveness of our approach through:
- Completion of modern-slavery awareness training (target: 100% of personnel each year).
- Coverage of material suppliers by a published modern-slavery commitment (statement, certification, or contract clause).
- Speak-Up reports received and resolved (with no identifying detail).
- Any material findings from supplier due-diligence assessments.
These metrics are reviewed annually by Blankstate’s executive ownership and reflected in the annual update of this statement.
8. Looking ahead
As Blankstate grows, we will:
- Continue to publish this voluntary statement annually, ahead of any statutory obligation arising.
- Extend formal modern-slavery clauses into all material new supplier contracts on renewal.
- Maintain proportionate due diligence as our customer base extends into regulated sectors with their own supplier obligations (financial services, public sector, healthcare).
- Continue to publish through the Trust Center.
9. Approval
This statement is approved by Blankstate’s executive ownership on behalf of the Board of Traceflow Ltd. It is reviewed annually and republished.