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Statement | Family 1, Corporate & Entity
Edsol Edtech Pvt. Ltd.'s statement on modern slavery, forced labour and child labour in its own operations and in its supply chain.
This document is the source of truth for: marketing:/legal/modern-slavery, trust:/policies/modern-slavery
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STM-GL-031 | Version 1.0.0 | Last Modified On 01 August 2026
Edsol Edtech Pvt. Ltd.'s statement on modern slavery, forced labour and child labour in its own
operations and in its supply chain.
Edsol Edtech Pvt. Ltd. is below the reporting threshold in every jurisdiction in which it operates and
has no statutory obligation to publish this statement. It publishes it voluntarily. The obligation
cascades: hospital groups, state health services and large not-for-profit operators are reporting
entities, and they discharge their obligation by sending supplier questionnaires. Having the answer
already written, published and dated turns a week-long questionnaire cycle into a link.
This document is the global source of truth. The Australian statutory-form statement is STM-AU-031,
derived from this one and restructured to the seven mandatory criteria of the Australian Act, with an
approval block. It does not restate anything here. In the Australian market, issue STM-AU-031;
elsewhere, issue this one.
| Jurisdiction | Instrument | Threshold | Edsol Edtech Pvt. Ltd.'s position |
|---|---|---|---|
| Australia | Modern Slavery Act 2018 (Cth) | Annual consolidated revenue of at least A$100 million for an entity carrying on business in Australia | Below threshold. Not a reporting entity. A statutory review has recommended lowering the threshold to A$50 million; that has not been implemented as at 01 August 2026 |
| India | Bonded Labour System (Abolition) Act, 1976; Child and Adolescent Labour (Prohibition and Regulation) Act, 1986; Sections of the Bharatiya Nyaya Sanhita, 2023 dealing with trafficking and forced labour | Applies to all employers | Applies. Complied with. No periodic public statement is required |
| Denmark, Norway | Norway's Transparency Act imposes due diligence and information duties on larger enterprises | Size thresholds apply | Below threshold [UNVERIFIED: confirm the current Norwegian Transparency Act thresholds and whether a foreign supplier to a covered enterprise incurs any direct duty, before relying on this row in a Norwegian tender.] |
| United Arab Emirates | Federal labour legislation prohibiting forced labour | Applies to employers in the UAE | Edsol Edtech Pvt. Ltd. has no establishment in the UAE and no personnel employed there |
Structure. Edsol Edtech Pvt. Ltd. is a Private Limited Company incorporated in
India, CIN [TO BE SUPPLIED], registered office
28, Jamunather Bulandshahar Uttar Pradesh India. Its group structure is at STM-GL-029.
Operations. Edsol Edtech Pvt. Ltd. designs, builds, deploys and operates Pensieve, an
operating system for hospitals. Its work is software engineering, deployment and support. It operates no
factory, no warehouse, no plantation, no mine and no construction site. Its personnel are
[TO BE SUPPLIED] employees engaged in engineering, implementation, support and administration.
Supply chain. Short, and almost entirely digital.
| Tier | What it consists of | Modern slavery risk assessment |
|---|---|---|
| Tier 1: cloud and platform | Google Cloud Platform (the infrastructure on which Pensieve runs), plus the software-as-a-service tooling listed in the subprocessor register DIS-GL-009 |
Low. Large listed suppliers with their own published statements and audited supply chains |
| Tier 1: professional services | Statutory auditor, legal advisers, insurance brokers, banking | Low. Regulated professions in India |
| Tier 2: contractors and freelancers | Pensieve contractor position |
Low, and directly controlled. Engaged individually, on written contracts, paid by bank transfer above the statutory minimum |
| Tier 3: hardware | None purchased or resold by Edsol Edtech Pvt. Ltd.. Hardware for a deployment is specified by Pensieve Labs and procured by the hospital directly from its own supplier |
Risk sits with the hospital's own procurement and is disclosed here rather than obscured |
| Tier 4: facilities | Office premises, utilities, cleaning and facilities services at Bulandshahar |
The highest residual risk in the chain, because facilities and cleaning services are a recognised risk sector. Addressed in section 4 |
The honest assessment.
Edsol Edtech Pvt. Ltd.'s modern slavery risk is genuinely low, and it is low because of what the business is, not because of what the company has done. The risk that does exist sits in facilities services and in the hardware manufacturing chain thatEdsol Edtech Pvt. Ltd.deliberately does not participate in. Saying so is more useful to a hospital's procurement team than an assurance that a low-risk business has a comprehensive programme.
Edsol Edtech Pvt. Ltd. does not, and will not:
Every person engaged by Edsol Edtech Pvt. Ltd. is engaged on a written contract stating the role,
the remuneration and the notice period, and is paid by bank transfer at not less than the applicable
statutory minimum wage. No personnel are engaged through a labour contractor.
| # | Action | Status as at 01 August 2026 |
|---|---|---|
| 1 | Written contracts and bank payment for all personnel | In place |
| 2 | Prohibition on labour contractors and on recruitment fees | In place, declared at STM-IN-016 Annexure B |
| 3 | Supplier undertakings from partners and subcontractors | Required before appointment. Terms mirror section 3 |
| 4 | Subprocessor register maintained and published | In place (DIS-GL-009) |
| 5 | Reporting channel for concerns, with non-retaliation | In place: info@pensievelabs.org and the channel published with POL-GL-059 |
| 6 | Written modern slavery clause in facilities and cleaning service contracts | Pensieve msa facilities clause status: this is the identified gap and is the one action this statement commits to closing |
| 7 | Annual review of this statement, approved by the board | Committed. Next review 31 July 2027 |
| 8 | Formal training programme | Not in place. For a company of [TO BE SUPPLIED] people with the supply chain described above, Edsol Edtech Pvt. Ltd. has judged a written standard and direct engagement to be proportionate, and says so rather than describing a programme it does not run |
Effectiveness. With a supply chain of this size, effectiveness is assessed by direct enquiry rather
than by audit metric: whether every person engaged has a written contract and is paid through the banking
system, whether any concern has been raised through the reporting channel, and whether the gap at row 6
has closed. Number of concerns raised in the period: Pensieve modern slavery reports count.
Where Edsol Edtech Pvt. Ltd. identifies or is credibly informed of modern slavery in its operations or
supply chain, it will: (a) prioritise the safety and remediation of the affected person over commercial
considerations and over its own reputation; (b) report to the appropriate authority where the law
requires or the circumstances warrant; (c) engage with the supplier concerned to remediate, and
disengage only where remediation fails or is refused, because abrupt disengagement can worsen the
position of the affected workers; and (d) notify any customer whose engagement is affected.
Concerns may be raised, including anonymously, at info@pensievelabs.org. No person raising a concern
in good faith will suffer any detriment.
This statement was approved by the Board of Directors of Edsol Edtech Pvt. Ltd. on
Pensieve modern slavery statement approved on and is signed by a director on its behalf. It covers
the financial year 1 April to 31 March.
| Signature | ____________________________ |
| Name | [TO BE SUPPLIED] |
| Designation | Director |
| DIN | [TO BE SUPPLIED] |
| Place | Bulandshahar |
| Date | 04 August 2026 |
Token registry additions required: entity.contractor_position,
entity.msa_facilities_clause_status, entity.modern_slavery_reports_count,
entity.modern_slavery_statement_approved_on.
| Subject | Document that owns it |
|---|---|
| Australian statutory-form statement | STM-AU-031 |
| Subprocessors and the digital supply chain | DIS-GL-009 |
| Anti-bribery and anti-corruption | STM-GL-030 |
| Labour and statutory compliance | STM-IN-016 Annexure B |
| Beneficial ownership and group structure | STM-GL-029 |
| Reporting channel and non-retaliation | POL-GL-059 |
| Version | Date | Author | Summary |
|---|---|---|---|
| 1.0.0 | 2026-07-31 | Legal | First issue. Voluntary statement below every applicable threshold, with a tiered supply-chain risk assessment naming facilities services as the highest residual risk, seven substantive commitments, and an actions table that records one open gap and one deliberately-not-implemented control rather than overstating the programme. |
STM-GL-031 v1.0.0 | Last Modified On 01 August 2026 | Edsol Edtech Pvt. Ltd. | CIN [TO BE SUPPLIED]