Modern Slavery Statement
UNICONS' annual statement on steps taken to prevent modern slavery and human trafficking in its operations and supply chain, published voluntarily in alignment with the Modern Slavery Act 2015.
1. Introduction and Commitment
This Modern Slavery Statement is published by LOPEX UNICONS LTD (trading as UNICONS), a company registered in England and Wales, with its registered office at 214 High Street, Second Floor, Hounslow, TW3 1HB, London, United Kingdom. This statement is published in respect of the financial year ending 31 August 2026.
UNICONS is committed to a zero-tolerance approach to modern slavery and human trafficking in all forms. Modern slavery is a grave violation of fundamental human rights. It encompasses slavery, servitude, forced and compulsory labour, and human trafficking — all of which involve the coercion, deception, or abuse of power over vulnerable individuals for the purpose of exploitation.
We recognise that the international student recruitment sector is one in which vulnerable individuals — young people seeking education, individuals moving across borders, those from economically disadvantaged backgrounds — can be exposed to exploitation. We therefore take our responsibility to identify and address modern slavery risks with the utmost seriousness.
UNICONS publishes this statement voluntarily. Although UNICONS does not currently meet the £36 million annual turnover threshold set by section 54 of the Modern Slavery Act 2015 that triggers mandatory reporting, we publish this statement as an expression of our genuine commitment to transparency and our obligations as a responsible organisation. We will continue to publish this statement annually as our business grows.
2. Organisation Structure and Supply Chain
Organisation:
UNICONS is a UK-based international education consultancy and technology platform operator. We connect international students with universities, colleges, and other accredited educational institutions in the United Kingdom and internationally. Our services include university admissions support, application management, counsellor and agent network management, and a proprietary digital platform through which students, agents, institutions, and counsellors interact.
UNICONS is headquartered in Hounslow, London. Our operations are UK-based, with services delivered to students and partners globally through our digital platform.
Supply chain:
UNICONS' supply chain is relatively compact and primarily service-oriented. It includes:
- IT and software service providers: Cloud infrastructure providers, software-as-a-service platforms, and managed IT services firms, the majority of which are established UK or US-headquartered companies with their own modern slavery compliance frameworks;
- Professional service firms: Legal, accountancy, and HR advisory firms engaged in the United Kingdom;
- International agents and counsellors: Individuals and organisations in various countries who recruit students on behalf of UNICONS under formal agency agreements. This is the area of our supply chain in which we consider modern slavery risk to be most significant, given the international scope and the nature of the relationship with potentially vulnerable individuals;
- Facilities and ancillary services: Office services suppliers based in the UK, including facilities management and courier services.
We do not manufacture goods and do not have a complex global manufacturing supply chain. Our modern slavery risks are concentrated in the direct delivery of student-facing services and in our international agent network.
3. Risks Identified in Our Sector
UNICONS has conducted a structured risk assessment of modern slavery and human trafficking risks across its operations and supply chain. We have identified the following as the most significant risk areas:
Exploitation of international students:
International students — particularly those from lower-income countries, those travelling alone, and those under 18 — may be vulnerable to exploitation by unscrupulous intermediaries. Risks include:
- *Debt bondage:* Students incurring unmanageable debts to recruiters or money lenders as a precondition of receiving assistance with their application;
- *Document retention:* Agents or informal intermediaries retaining a student's passport, offer letter, or other identity documents as a form of control;
- *Misrepresentation:* Students being misled about the nature, cost, or outcome of their studies, placing them in a position of dependency or vulnerability on arrival in the UK;
- *Labour exploitation upon arrival:* Students being coerced into employment arrangements that breach their visa conditions, particularly where an employer or accommodation provider was arranged by the same intermediary who arranged their studies.
Forced labour in supply chains:
Although UNICONS' supply chain is primarily composed of professional services, we recognise that IT hardware and ancillary services may involve lower tiers of supply chains in which labour exploitation is a known risk, particularly in certain jurisdictions.
Visa fraud facilitating trafficking:
The abuse of student visa processes to facilitate the trafficking of individuals to the United Kingdom is a recognised risk in the international education sector. UNICONS is aware that agents who operate without adequate oversight may be exploited as a conduit for such abuses.
Vulnerability of agents themselves:
In some jurisdictions, individuals who work as education agents may themselves be in vulnerable working conditions, working without formal contracts, social protection, or recourse to labour rights. UNICONS takes steps to ensure that the agents it works with are properly engaged and fairly treated.
4. Due Diligence Steps Taken
In response to the risks identified above, UNICONS has taken the following due diligence steps during the reporting period:
Agent vetting and approval process:
- All agents applying to join the UNICONS platform undergo a multi-stage vetting process before being approved. This includes identity verification, business registration checks, reference checks, and a review of the agent's trading history and reputation;
- Agents are required to confirm in writing their commitment to UNICONS' Code of Conduct for Agents, which includes explicit provisions prohibiting the exploitation of students, document retention, debt bondage, and any form of coercion;
- Agents are required to confirm compliance with applicable laws in their jurisdiction of operation, including any laws relating to modern slavery or human trafficking;
- UNICONS maintains the right to conduct unannounced compliance audits of agent operations and to terminate the engagement of any agent found to have breached its obligations.
Contractual obligations on agents regarding student protection:
- All agent agreements contain binding obligations to treat students fairly and ethically, to provide accurate and truthful information, and to refrain from any conduct that could constitute exploitation or abuse;
- Agents are required to report any concerns about student welfare — including any indicators of trafficking, exploitation, or document retention — to UNICONS promptly;
- Contracts contain right-to-audit provisions enabling UNICONS to request evidence of compliance.
KYC (Know Your Client/Counterparty) checks:
- UNICONS conducts proportionate Know Your Counterparty (KYC) checks on new agents and significant partners at onboarding, including sanctions list screening and adverse media checks;
- High-risk markets are subject to enhanced due diligence, which may include obtaining local legal advice on agent compliance with applicable laws.
Student welfare safeguards on platform:
- Students are provided with accessible information about their rights and about how to report concerns;
- Students who are under 18 are subject to additional platform safeguards, including parental consent requirements and restricted direct messaging;
- The UNICONS platform provides students with a confidential mechanism to report concerns about their agent, their counsellor, or any other party involved in their application.
Staff training:
All UNICONS staff members who interact with agents, students, or partner institutions have received training on: - The definitions and indicators of modern slavery and human trafficking; - The specific risks in the international education recruitment sector; - How to identify and report a concern; - UNICONS' reporting procedure and the legal protections available to persons who report in good faith.
5. Key Performance Indicators
UNICONS tracks the following key performance indicators (KPIs) to measure the effectiveness of its modern slavery prevention activities:
| KPI | Target | Result (Year Ending 31 August 2026) |
|---|---|---|
| Proportion of active agents who have completed vetting process | 100% | Reported in annual compliance review |
| Proportion of staff who have completed modern slavery awareness training | 100% | Reported in annual compliance review |
| Number of modern slavery or exploitation concerns reported via UNICONS channels | Tracked and investigated | Reported in annual compliance review |
| Proportion of concerns reported that were formally investigated within 5 working days | 100% | Reported in annual compliance review |
| Number of agent agreements terminated due to welfare or compliance breach | Tracked | Reported in annual compliance review |
UNICONS is committed to improving its KPI framework and the granularity of data it collects in this area as its compliance infrastructure matures. KPI results will be included in future iterations of this statement.
6. Training Provided
UNICONS provides the following training in relation to modern slavery and human trafficking:
For all employees:
A mandatory module on modern slavery awareness, covering: - What modern slavery is and the forms it takes; - Why the international education sector faces particular risks; - The indicators of exploitation that may be visible in student-facing work; - How to report a concern — internally to the Designated Safeguarding Lead and externally to the Modern Slavery Helpline or statutory authorities.
Training is completed at induction and refreshed annually. Completion is recorded.
For agents and counsellors:
All agents and counsellors who join the UNICONS platform are provided with a briefing document and online module covering: - UNICONS' zero-tolerance stance on exploitation of students; - The behaviours prohibited by the UNICONS Code of Conduct for Agents; - How to recognise and report indicators of exploitation or trafficking in relation to students they work with.
Completion of this briefing is a condition of platform activation.
For management:
Senior UNICONS management participates in annual training that addresses modern slavery risk assessment, supply chain due diligence, and the organisation's legal obligations under the Modern Slavery Act 2015 and related legislation.
7. How to Report Concerns
UNICONS encourages all students, staff, agents, counsellors, and members of the public to report any concern about modern slavery, human trafficking, or exploitation in connection with UNICONS' operations or supply chain.
Internal reporting:
Concerns may be reported to UNICONS at: - Email: enquiry@unicons.co.uk (subject line: MODERN SLAVERY CONCERN — CONFIDENTIAL) - Post: LOPEX UNICONS LTD, 214 High Street, Second Floor, Hounslow, TW3 1HB, London, United Kingdom (marked: CONFIDENTIAL)
All reports will be treated with the strictest confidentiality and will be investigated promptly. Persons who report genuine concerns in good faith will not suffer any detriment as a result.
For concerns that relate to the safeguarding of a child or vulnerable adult, please also refer to the UNICONS Safeguarding and Student Welfare Policy, which sets out additional reporting pathways including escalation to statutory authorities.
External reporting:
| Organisation | Contact |
|---|---|
| Modern Slavery Helpline (UK) | 08000 121 700 (24/7, free, confidential) |
| National Crime Agency (UKHTC) | www.nationalcrimeagency.gov.uk |
| Police (non-emergency) | 101 |
| Emergency services (immediate risk to life) | 999 |
| Gangmasters and Labour Abuse Authority (GLAA) | 0800 432 0804 |
UNICONS cooperates fully with statutory authorities investigating modern slavery or human trafficking concerns and will provide all available information upon lawful request.
8. Statement Approval, Signatories, and Review
This Modern Slavery Statement has been approved by the Board of Directors of LOPEX UNICONS LTD and reflects the steps taken by UNICONS during the financial year ending 31 August 2026 to identify and address modern slavery risks in its operations and supply chain.
Approved by:
[Director's name — to be signed] Director LOPEX UNICONS LTD 214 High Street, Second Floor, Hounslow, TW3 1HB, London, United Kingdom
Date of approval: 1 September 2025
Publication: This statement is published on the UNICONS website at www.unicons.co.uk/legal/modern-slavery in accordance with our commitment to transparency. It is also registered on the UK Government's Modern Slavery Statement Registry at www.modern-slavery-statement-registry.service.gov.uk.
Review period: This statement is reviewed and updated annually. The next statement, covering the financial year ending 31 August 2027, will be published by 30 September 2027.
Note on mandatory reporting threshold: Section 54 of the Modern Slavery Act 2015 requires organisations with a global annual turnover of £36 million or more to publish an annual modern slavery statement. UNICONS publishes this statement voluntarily, as an expression of our commitment to ethical business practice and in anticipation of our continued growth. We are committed to maintaining this practice as our organisation develops.
