Modern Slavery and Human Trafficking Statement
Smart City Operating System Limited (trading as scOS)
1. Status of this statement
This is a voluntary statement. It is not published under section 54 of the Modern Slavery Act 2015.
Smart City Operating System Limited supplies goods and services and carries on business in the United Kingdom, but its turnover is far below the £36 million threshold prescribed by regulation 2 of the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. We therefore have no duty to prepare a slavery and human trafficking statement.
We publish this statement because we want partners, customers and anyone in our supply chain to see, in plain terms, what we actually do. The content follows the topics listed in section 54(5) of the Act as a useful structure. Using that structure does not create a statutory obligation.
Modern slavery: slavery, servitude, forced or compulsory labour, and human trafficking: is a crime and a violation of fundamental human rights. We have a zero-tolerance approach to it in our business and in our supply chain.
This statement describes our position as at 7 October 2026. We will review it at least once a year, and sooner if our size, our supply chain or our position against the section 54 threshold changes.
2. Our organisation and business
This statement is made by Smart City Operating System Limited, a private company limited by shares registered in England and Wales under company number 13569571.
- Registered office: 71 Manor Road, Caddington, Luton, LU1 4EE, United Kingdom
- Correspondence address: 4th Floor, Silverstream House, 45 Fitzroy Street, London, W1T 6EB, United Kingdom
- Trading name: scOS. scOS is a trading name of the company, not a separate legal person.
Companies House record: 13569571
We are a very small, UK-based company. We have a single director and, at the date of this statement, no employees. Work is done by the director and, where needed, by specialist contractors and professional advisers engaged on ordinary commercial terms.
Our main product is software: an AI-assisted home and property security service, delivered on subscription. The service uses a small on-premises device, the scOS Intelligence Hub, together with cloud software for monitoring, verification and related features. We serve customers in the United Kingdom.
The hub is assembled and provisioned by us from third-party compute boards and related components, purchased as finished goods. We do not fabricate semiconductors or printed circuit boards.
We do not manufacture, brand, supply or import cameras. Any camera used with the service is the customer's, a third-party installer's, or a partner's.
Because our own operations are UK-based, director-led and skilled, we assess the risk of modern slavery inside the company as low. The greater inherent risk sits upstream of the electronic components we buy, as described below.
Responsibility for this statement, and for the steps it describes, sits with the sole director.
3. Our supply chains
We do not operate a factory and we do not have manufacturing partners. Our supply chain is short and matches the size of the business.
What we buy and use
- Compute boards and related electronics: commercially available boards and components, purchased as finished goods from established distributors or retailers, then assembled and provisioned by us as hubs.
- Cloud, connectivity and payments: computing, networking and payment-processing services from established technology and financial-services providers.
- Professional services: legal, accountancy, insurance and similar advisers, and specialist contractors, typically UK-based.
- Delivery: where we ship a hub, established courier services.
What we do not buy to sell
Cameras are outside our supply chain as a product we manufacture or on-sell.
Where the risk sits
Our direct purchases are predominantly from established suppliers serving the UK market and subject to UK law. We do not have visibility of the tiers below those suppliers. We recognise that semiconductors, raw-material extraction and overseas electronics manufacturing can reach jurisdictions and labour markets with a higher inherent risk of forced labour. That extended electronics chain is the part of our business with the greatest inherent modern-slavery risk. We do not pretend to have mapped it.
Labour in our own business is the director and a small number of skilled contractors. We do not use agencies, gangmasters or overseas labour-hire for our own work.
4. Our policies
We do not yet have a standalone modern-slavery policy or a supplier code of conduct. Inventing one for this page would overstate what a company of our size currently operates. The rules we do apply are these:
- Zero tolerance. We will not use, and will not knowingly buy from anyone who uses, slavery, servitude, forced or compulsory labour, bonded labour, child labour or human trafficking.
- Lawful engagement. The director and any contractor or adviser is engaged on lawful, arm's-length terms. We do not use unpaid, forced or coerced labour. When we take on employees or workers, we will carry out right-to-work checks and pay at least the applicable statutory minimum.
- Supplier expectation. We expect every supplier to comply with the law that applies to them: including, if they are themselves in scope, section 54 of the Modern Slavery Act 2015, and not to use forced, bonded or child labour. We expect them to hold their own suppliers to an equivalent standard. We will put that expectation into written supplier terms when our procurement volume justifies it.
- Speak up. Anyone in or dealing with our business can raise a concern about modern slavery using the contact details at the end of this statement. We will look into any credible concern and take appropriate action.
As the company grows we will write these rules down as formal policies. This statement will say so when that has actually happened.
5. Due diligence and risk management
The steps we take are proportionate to a very small company. They are:
- buying compute boards and components as finished goods from established suppliers, rather than contracting overseas manufacture ourselves;
- keeping assembly and provisioning in our own hands, which shortens the chain we can see;
- not putting cameras into our product supply chain;
- preferring, where it is commercially practical, UK or otherwise well-known providers for cloud, payments, professional services and delivery;
- giving anyone a route to raise a concern, and investigating if one is raised.
We do not currently run supplier audits, modern-slavery questionnaires, or a contractual supplier-code programme. We will add written modern-slavery wording to material supplier contracts, and ask those suppliers for their own statement or policy, as those relationships become standing rather than one-off purchases.
On that basis we regard the risk of modern slavery in our own UK operations as low. The residual risk is in the extended electronics supply chain behind the boards we buy. We manage that residual risk today by supplier selection and by not building a longer chain than the product needs. We will say in the next version of this statement if that changes.
If we found modern slavery in our business or supply chain we would put the affected people first, take advice, report to the appropriate authority where we should, and only then decide whether we can stay in the relationship.
6. Training: as we grow
There is no staff training programme, because there is no staff.
The director maintains an awareness of modern-slavery risk in electronics supply chains and in a small UK services business. When we employ people, or when anyone other than the director regularly buys from or manages suppliers, we will give those people a modern-slavery briefing so they can recognise and escalate a concern. We will record that in the next statement after it starts.
7. How we will tell if this is working
We do not operate modern-slavery performance indicators. Measuring the percentage of suppliers on a code we have not written would be theatre.
When the business is large enough for formal measures to mean something, we intend to track:
- whether each material supplier has given us their own modern-slavery statement or accepted written terms that prohibit forced, bonded and child labour;
- the number of concerns raised, and what we did;
- whether anyone who procures or manages suppliers has had the briefing in section 6.
We will report those figures when we have them.
8. How to raise a concern
If you are worried that slavery or human trafficking is taking place in our business or supply chain, or you have a question about this statement, please contact us. You do not need to be a customer.
- Contact: Contact Us
- Post (correspondence): Smart City Operating System Limited, 4th Floor, Silverstream House, 45 Fitzroy Street, London W1T 6EB, United Kingdom
- Registered office (legal notices): 71 Manor Road, Caddington, Luton LU1 4EE, United Kingdom
If someone is in immediate danger, contact the police on 999. In the UK, modern slavery can also be reported to the Modern Slavery Helpline on 08000 121 700.
9. Approval
This is a voluntary statement. It is not a statement under section 54 of the Modern Slavery Act 2015.
The sole director has approved this statement under Model Article 7(2).
Name: Flynn David Robinson
Office: Director
For: Smart City Operating System Limited (company no. 13569571)
Date: 18 October 2026