Ethical Recruitment and Labour Standards Policy

1. Purpose

This policy sets the minimum recruitment and labour standards BONDAP applies whenever it brings someone into its workforce — as an employee, a contractor or freelancer, or an agency or temporary worker — and the standards it expects any recruitment agency or labour provider acting on its behalf to meet. It gives practical effect to the Anti-Slavery and Human Trafficking Policy and to the Employer Pays Principle: no worker ever pays, directly or indirectly, to get or keep a job with BONDAP.

2. Scope

This policy applies to everyone who works for BONDAP, however engaged:

• Direct hires — employees and workers on a BONDAP LTD or BONDAP Sp. z o.o. contract of employment;
• Contractors and freelancers — individuals engaged directly by BONDAP under a contract for services, whether sole traders or through a personal service company;
• Agency and temporary workers — anyone supplied to BONDAP by a recruitment agency, staffing business, or other labour provider, whether working alongside staff or performing project-based work; and
• Subcontracted individuals — people performing work for BONDAP through an outsourced team or subcontractor, where BONDAP does not contract with the individual directly but relies on another organisation's workforce.

BONDAP is a micro company (fewer than 10 employees), so most of this workforce is small and known to us personally. The standards below are proportionate to that scale, but apply without exception — size is not a reason to relax a right-to-work check or accept a recruitment fee.

3. Direct-hire standards

Before anyone starts work for BONDAP as an employee or worker, the CEO (or a director) must ensure:

• Right-to-work check completed and recorded. A right-to-work check is carried out and passed under the Immigration, Asylum and Nationality Act 2006 before the start date. Original identity and immigration documents are inspected in person (or via the Home Office online/IDVT route) and verified as genuine, but originals are never retained by BONDAP — they are checked, copied where the law requires a copy, and returned immediately. A dated record of the check (what was checked, by whom, and the outcome) is kept on the worker's file for as long as required by law.
• Written terms before or on day one. A written contract or, at minimum, a statement of written particulars compliant with the Employment Rights Act 1996 is provided before the start date or no later than day one, in plain English or another language the worker understands (arranging translation or a plain-language summary where needed). Polish labour law (Kodeks pracy) governs the equivalent documentation for BONDAP Sp. z o.o. employees.
• Pay at or above the legal minimum, on time, direct to the worker. Pay meets or exceeds the National Minimum Wage Act 1998 rate for the worker's age band (or the applicable Polish minimum for Sp. z o.o. staff), is paid on the agreed date, and is paid into a bank account in the worker's own name — never to a third party, agency, or "representative."
• Working hours within legal limits. Hours comply with the Working Time Regulations 1998 (or Polish equivalent), including the 48-hour weekly average unless a worker has validly opted out in writing, and statutory rest breaks and holiday entitlement are honoured.
• No recruitment fees or deposits, ever. No candidate is charged, directly or indirectly, for an interview, a job offer, a right-to-work check, equipment, training, or anything else connected with getting or keeping a role at BONDAP. This is the Employer Pays Principle: recruitment costs are BONDAP's to bear, not the worker's.
• Freedom to resign and freedom of movement. Workers can resign on their contractual notice without penalty, and are never asked to surrender personal property (passports, phones, bank cards) or have their movement restricted as a condition of employment.

4. Extra protections for vulnerable groups

BONDAP has identified domestic and foreign migrant workers, contract/agency/temporary workers, refugees, young or student workers, and women in low-paid or outsourced work as groups at higher risk of exploitation, in our own workforce and in our clients' and suppliers' workforces. Temporary labour is one of our highest-risk categories generally. For anyone in these groups joining BONDAP directly, the person handling onboarding must complete all of the following in addition to the standard checks in section 3, and must record on the worker's file that each was done:

• Confirm in conversation — not just by a signature — that the worker understands their pay rate, hours, and notice terms, using an interpreter or translated summary if there is any doubt about comprehension;
• Ask, sensitively, whether anyone else arranged the job for them, and if so, whether that person or agency charged a fee or is owed money by the worker;
• Check that the worker is dealing directly with BONDAP about their own pay and bank details, with no third party collecting on their behalf, holding their documents, or controlling their housing or transport;
• For workers under 18 or in full-time education, confirm hours and any study/work balance are appropriate and lawful, and that a parent or guardian is aware where relevant;
• Note anything that does not add up (a "manager" who insists on speaking for the worker, reluctance to discuss pay, a bank account not in the worker's name) as a red flag under section 7.

5. Recruitment agencies and labour providers

BONDAP does not currently maintain a full record of where recruitment agencies are used across its extended workforce. From the effective date of this policy, that changes:

• Vetting before use. Any recruitment agency or labour provider is assessed under the Supplier Due Diligence Procedure and Modern Slavery Questionnaire before it is used, not after.
• Licensing and regulatory status. Gangmasters and Labour Abuse Authority licensing applies only where the sector requires it — labour providers in agriculture, horticulture, shellfish gathering, and associated food processing and packaging — which will rarely cover BONDAP's own hiring. Where it does apply, BONDAP checks the agency holds a valid GLAA licence before engaging it and re-checks that status at least annually for ongoing relationships. For every other agency, BONDAP confirms it operates in compliance with the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003, including the prohibition on charging work-seekers a fee for finding work.
• Written no-fees confirmation. BONDAP obtains written confirmation from every agency it uses that it does not charge candidates or placed workers any fee, deposit, or other cost for finding or keeping work with BONDAP.
• Agency register. The CRO maintains a register of every recruitment agency and labour provider used by BONDAP, recording the agency's name, licensing status (where applicable), the roles or workers supplied, and the date the Modern Slavery Questionnaire was last completed. This register is reviewed at least annually and forms part of the CRO's quarterly risk reporting to the Board.

6. Contractors and subcontracted teams

Where BONDAP engages contractors, freelancers, or an outsourced team rather than direct hires:

• The relevant contract manager must know, and record, whether each individual performing work under the contract is employed or self-employed, and on what basic terms (directly engaged, subcontracted, or supplied via an agency).
• Contract managers must not assume a subcontractor's workforce is compliant by default. Where a subcontracted individual performs work for BONDAP on more than 20 days in any 12-month period, the contract manager must obtain written confirmation from the subcontracting organisation that the standards in section 3 apply to that individual, and must escalate to the CRO within 5 business days if the confirmation is not given, is unclear, or is unsatisfactory.
• Standard Model Contract Clauses — Modern Slavery are used in contractor and outsourcing agreements to make these expectations contractual, not just aspirational.

7. Red flags and the duty to report

Anyone involved in hiring, onboarding, or managing contractors, agency workers, or subcontracted staff must treat the following as reasons to stop and ask questions rather than proceed, and must raise anything unresolved with the CRO:

• A candidate or worker who cannot answer basic questions about their own pay or hours, or defers every question to someone else present;
• Bank details for pay that are not in the worker's own name;
• An agency or subcontractor that is reluctant to confirm who it employs, how it pays them, or whether it charges any fees;
• A worker who appears to be under pressure to accept terms quickly, or who mentions owing money connected to getting the job;
• Any of the broader red flags set out in the Anti-Slavery and Human Trafficking Policy.

Any concern, however small, must be raised under the Whistleblowing and Modern Slavery Reporting Policy. Confirmed or suspected incidents are then handled under the Modern Slavery Incident Response and Remediation Procedure. No one will be penalised for raising a genuine concern about a colleague, agency, or subcontractor in good faith.

8. Record-keeping and oversight

Right-to-work check records, written particulars/contracts, agency Modern Slavery Questionnaires, and the agency register are kept by the CEO and CRO respectively, retained for the period required by applicable employment and immigration law, and made available to the Board on request. The CRO has overall oversight of compliance with this policy, reviews the agency register and any red flags raised at least quarterly, and reports a summary to the Board alongside other modern slavery risk reporting. This policy operates alongside, and does not replace, the Workforce Matters Policy, Diversity and Equality Policy, Complaints Policy and Procedure, and Work Health and Safety Policy.

9. Consequences of breach

Any manager, director, or staff member who fails to carry out required checks, or who knowingly engages a worker on non-compliant terms, will be dealt with under BONDAP's disciplinary procedures, up to and including dismissal. Any recruitment agency, labour provider, contractor, or subcontractor found to have charged worker fees, falsified checks, or otherwise breached the standards in this policy will have its engagement suspended pending investigation and, where the breach is confirmed, terminated, in line with the Supplier Code of Conduct and Model Contract Clauses.

10. Governance, review and approval

This policy is owned by the CRO, forms part of the Risk Management Framework owned by the CEO, and was approved by the Board of Directors, taking effect on the effective date above. It will be reviewed at least annually, or sooner following a modern slavery incident, a material change to how BONDAP recruits or engages its extended workforce, or a 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.