1. Introduction
This statement is published voluntarily by Lightstart Universal Limited ("the Company") to set out the steps we have taken, and continue to take, to ensure that slavery and human trafficking are not taking place in any part of our own business or in our supply chains.
Although the Company currently falls outside the statutory scope for mandatory publication of a transparency statement under the Modern Slavery Act 2015, we are committed to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to guard against modern slavery and human trafficking occurring anywhere in our business or supply chains.
2. Organisational Structure and Business
Lightstart Universal Limited is incorporated in Nigeria under the Companies and Allied Matters Act 2020 with its registered office at 1 Rima Street, Maitama, Abuja.
The Company operates in the compliance software (RegTech) sector, providing regulatory compliance and risk management software to clients in Nigeria and internationally.
3. Our Supply Chains
As a software company, our supply chains are primarily made up of technology and professional services suppliers, including cloud hosting and infrastructure providers, software vendors, and IT support contractors.
We work with companies based in Nigeria and internationally and recognise that certain suppliers and geographies carry a higher inherent risk of modern slavery and labour exploitation.
4. Our Anti-Slavery Policies
We operate internal policies to ensure that we conduct business in an ethical and transparent manner. These include:
- Fair Pay: We ensure all employees and contractors are paid a fair wage in line with applicable local labor laws.
- Whistleblowing Policy: We maintain an open culture where all employees, suppliers, and partners can report concerns about working conditions without fear of retaliation.
- Ethical Sourcing: We clearly communicate our expectations regarding worker safety, fair hours, and voluntary employment to our partners.
5. Due Diligence Processes
We manage risks by checking who we do business with. We do this by:
- Ensuring all staff members have legal employment contracts and work voluntarily.
- Refusing to work with any supplier or entity known to violate basic human rights or child labor laws.
6. Commitment to Continuous Improvement
We understand that mitigating modern slavery risks requires continuous effort. We will review our supply chains annually to maintain high ethical standards as our business grows.
7. Risk Assessment and Management
We assess the risk of modern slavery occurring within our business and supply chains by reference to factors such as geography, sector, and the nature of the labour involved.
8. Looking Ahead
In the coming financial year, we intend to strengthen our due diligence procedures, reinforce staff training and carry out a review of our Code of Conduct where necessary.
We will continue to monitor our turnover against the statutory threshold under section 54 of the Modern Slavery Act 2015 and will comply with the mandatory reporting requirements should the Company come within scope in future.
9. Approval
This statement is made voluntarily and constitutes Lightstart Limited's modern slavery and human trafficking transparency statement for the financial year ending 31 December 2025.
Tola Onayemi
Managing Director / CEO
