Anti-Slavery and Human Trafficking Policy

1. Purpose and policy statement

BONDAP LTD has zero tolerance for slavery and human trafficking in any form, in any part of our business or our supply chains. This policy sets out what that means in practice for a technology consulting and SaaS business of our size, and it is the cornerstone document of our wider modern slavery policy pack (see section 9).

We are committed to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking are not taking place anywhere in our own operations or in the supply chains that support our products (B-SAFE, B-CRM, Freibaum, Hovix), our e-commerce, hosting, web development, help desk, training and systems support services.

This policy applies alongside, and does not replace, our legal obligations. It also underpins our voluntary Modern Slavery Statement, which we publish following the transparency provision in s.54 of the UK Modern Slavery Act 2015 and the equivalent reporting regimes under the Australian Modern Slavery Act 2018 and the California Transparency in Supply Chains Act, even though none of those regimes currently obliges us to report — we are below the s.54 turnover threshold, and the Australian and Californian regimes turn on carrying on business in Australia and on being a retail seller or manufacturer doing business in California respectively.

2. Scope

This policy applies to:

• All directors, employees, and workers of BONDAP LTD, however senior, and all workers of BONDAP Sp. z o.o. where this policy has been adopted by its management board;
• Contractors, freelancers, agency workers, and consultants engaged by BONDAP LTD, whether on-site, remote, or engaged through a third party;
• Suppliers, subcontractors, and business partners, who are expected to comply with the standards in this policy and in our Supplier Code of Conduct as a condition of doing business with us.

Because BONDAP is a micro company (fewer than 10 employees) with no in-house factories, warehouses, or manual labour force, our own direct workforce risk is low. Our exposure to modern slavery risk arises principally through our supply chains and through the sectors our clients operate in (including construction-adjacent clients via Freibaum). This policy is written accordingly — it does not attempt to replicate large-corporate committee structures we cannot staff.

3. What modern slavery is

"Modern slavery" is used as shorthand for a group of offences grounded in the ILO core conventions and reflected in the Modern Slavery Act 2015: slavery, servitude, forced or compulsory labour, and human trafficking. Related and overlapping practices include debt bondage, child labour, and deceptive recruiting. Short examples relevant to our supply chains:

• Forced labour / debt bondage — a cleaning contractor's staff who have had recruitment fees deducted from their wages and cannot leave without paying off a "debt" to a labour agency.
• Deceptive recruiting — a temporary IT support worker recruited abroad on promises of one role and pay rate, then given different, worse terms on arrival, with wages or hours changed unilaterally.
• Servitude / controlled workers — subcontracted catering or facilities staff at a client site whose passports or ID documents are held by a supervisor, or who are housed and transported only by their employer and cannot come and go freely.
• Human trafficking — workers supplied through an unregistered labour agency for a promotional-goods or print-merchandise order, moved between sites, and unable to confirm who actually employs them.
• Child labour — underage workers used in a low-cost promotional goods or electronics-assembly supply chain feeding IT equipment we procure.

These are illustrative, not exhaustive. Any credible indication of these practices, however minor it may seem, must be raised (see section 7).

4. Responsibilities

5. Risk areas specific to BONDAP

Our risk assessment (feeding the Risk and Control Register under the RMF) focuses on:

Highest-risk procurement categories: construction and land development (relevant via Freibaum's construction-sector clients and any premises work), cleaning, catering, promotional goods/merchandise, and temporary labour. Purchases in these categories require enhanced due diligence under the Supplier Due Diligence Procedure and Modern Slavery Questionnaire.

Vulnerable groups we must be alert to: domestic and foreign migrant workers, contract/agency/temporary workers, refugees, young or student workers, and women in low-paid or outsourced roles — the workforce in our cleaning and catering risk categories skews female — wherever they appear in our supply chains or in the workforces of clients and suppliers we deal with.

Main supply chains: IT equipment and services, business and trading services, and professional services. While generally lower risk than the categories above, IT hardware supply chains can involve long, opaque manufacturing and assembly chains where risk is harder to see, so any supplier with total expected spend above £10,000 per annum, across all contracts with that supplier, is treated as at least Medium tier and receives the enhanced due diligence set out in the Supplier Due Diligence Procedure and Modern Slavery Questionnaire, whatever its category. Geography is scored alongside category and spend under that procedure, so a low-category supplier in a higher-risk country is also caught.

6. What compliance looks like day to day

Staff do not need to be investigators, but everyone is expected to notice and report obvious warning signs when dealing with suppliers, contractors, client sites, or subcontracted staff. Red flags include:

• Workers who appear frightened, withdrawn, or unwilling to speak for themselves, or who are always accompanied by a "minder" who answers on their behalf;
• Workers whose identity documents, passports, or bank cards are held by an employer or agency rather than the worker themselves;
• Signs of debt to an employer or recruiter, or wages paid in full or in part to a third party rather than the worker;
• Same address given for multiple unrelated workers, or workers transported to and from a site as a group with no freedom to travel independently;
• Unexplained or informal sub-contracting of labour, especially by cleaning, catering, or construction-adjacent suppliers, where the entity actually paying and directing the workers is unclear;
• Quotes or day rates that are implausibly low to sustain National Minimum Wage and statutory costs for the work described;
• Reluctance or refusal by a supplier to answer questions in the Modern Slavery Questionnaire, or to allow basic verification of who is employed and how they are paid;
• Workers who appear to be under 18 doing work inconsistent with that age, or unable to produce evidence of age or right-to-work status.

Any one of these does not prove modern slavery is occurring, but it is enough to raise a concern (section 7). Staff must never confront a suspected trafficker or perpetrator directly.

7. Raising concerns and prohibition on retaliation

We want concerns raised early, even where someone is not certain. No one who raises a genuine concern in good faith will suffer retaliation, disadvantage, or detriment as a result, whether they are a member of staff, a contractor, or a supplier's worker. Retaliation against someone for raising a concern is itself a disciplinary matter under this policy.

Routes to raise a concern:

• Internally, via the process set out in the Whistleblowing and Modern Slavery Reporting Policy, or directly to the CRO / Modern Slavery Lead at speakup@bondap.com;
• Anonymously, if preferred: email speakup@bondap.com from an account that does not identify you, or write to "CRO — Private & Confidential", BONDAP LTD, 5 South Charlotte Street, Edinburgh EH2 4AN. The external routes below can also be used anonymously;
• Externally, to the UK Modern Slavery & Exploitation Helpline on 08000 121 700 (free, confidential, 24/7), or to the Gangmasters and Labour Abuse Authority (GLAA) where labour exploitation in a regulated sector is suspected;
• In an emergency, or where anyone is in immediate danger, call 999 (or the local police emergency number) first.

Concerns about a specific incident are then handled under the Modern Slavery Incident Response and Remediation Procedure.

8. Consequences of breach

Any employee, director, contractor, or agency worker found to have breached this policy, or to have knowingly facilitated modern slavery, will face disciplinary action up to and including summary dismissal (or termination of engagement, for non-employees), and may be reported to the relevant authorities. Suppliers or business partners found to be in breach, or who fail to cooperate with due diligence and remediation requirements, will face contract review, remedial action plans, and — where risk cannot be adequately mitigated — termination of the supplier contract, in line with the Supplier Code of Conduct and Model Contract Clauses.

9. Relationship to the Modern Slavery Statement and the wider policy pack

This policy gives effect to the commitments made in our annual Modern Slavery Statement. It sits alongside seven other documents in the pack, and alongside our existing Social Value Policy, Supply Chain Management Policy, Workforce Matters Policy, Diversity and Equality Policy, Complaints Policy and Procedure, and Work Health and Safety Policy.

10. Governance, review and approval

This policy is owned by the CRO and forms part of the Risk Management Framework owned by the CEO, with quarterly risk reporting to the Board. It was approved by the Board of Directors and takes effect on the effective date above; it will be reviewed at least annually, or sooner following any modern slavery incident, material change to our supply chains, or relevant change in law. Any material revision requires Board approval.

© BONDAP LTD. This document is the property of Bondap and is published for information only. It may not be copied, reproduced, adapted, distributed or used for any purpose without our prior written consent.