| Document owner | Chief Risk Officer |
| Approved by | Board of Directors |
| Version | 1.0 |
| Effective date | 1 August 2026 |
| Next review | 1 August 2027 |
| Applies to | BONDAP LTD and, where adopted by its management board, BONDAP Sp. z o.o. |
1. Purpose
Our published Modern Slavery Statement commits BONDAP to "conducting awareness training sessions on modern slavery for relevant personnel" and to evaluating the effectiveness of our actions annually. This policy sets out how we deliver that commitment in a way that is proportionate to a micro company of fewer than 10 people: no bought learning-management-system licence, no mandatory e-learning platform, but a genuine, recorded programme built on free, reputable UK materials, refreshed annually and after any incident or material policy change.
Training exists so that everyone at BONDAP can recognise the red-flag indicators set out in our Anti-Slavery and Human Trafficking Policy, knows how to raise a concern under our Whistleblowing and Modern Slavery Reporting Policy, and — for those with procurement, contracting, or recruitment responsibilities — can put our due diligence and contracting controls into practice.
2. Who is trained, and to what depth
| Audience | Depth and content | Typical format |
|---|---|---|
| All staff (including directors and any regular contractors/consultants) | Annual awareness session (~45–60 minutes): what modern slavery is, our highest-risk procurement categories and vulnerable groups, red-flag indicators, and how and where to report a concern. | Single all-hands session, delivered in person or via video call. |
| Directors and the CRO | Everything above, plus a deeper briefing: 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 (none of which currently obliges BONDAP to report — hence our voluntary Statement — and why we report anyway); the supplier due diligence process; and the Modern Slavery Incident Response and Remediation Procedure. | All-hands session plus a shorter dedicated director/CRO briefing, at least annually. |
| Contract managers and anyone involved in procurement or recruitment | Everything all staff receive, plus role-specific training: evaluating responses to the Modern Slavery Questionnaire, applying the Model Contract Clauses — Modern Slavery, and agency/recruiter vetting under the Ethical Recruitment and Labour Standards Policy. | All-hands session plus a role-specific briefing when the person takes on the responsibility, and refreshed annually. |
Where one individual holds more than one of these roles (common at our size — for example, the CRO is also a contract manager), the deeper content applies and is not repeated separately.
3. Onboarding rule
New joiners — employees, directors, and any contractor or consultant engaged on an ongoing basis — must complete the all-staff awareness session (or a short one-to-one equivalent, delivered by the CRO where the next scheduled group session falls more than 30 days after the start date) within 30 days of their start date. Anyone taking on a procurement, recruitment, or contract-management responsibility must complete the relevant role-specific briefing before they independently evaluate a Modern Slavery Questionnaire, sign off a supplier contract, or engage a recruitment agency, whichever comes first.
4. Refresher cadence
Training is refreshed:
- Annually, for all audiences, timed to align with the review of this policy pack and the preparation of the annual Modern Slavery Statement; and
- Ad hoc, promptly following any confirmed or suspected modern slavery incident (see the Modern Slavery Incident Response and Remediation Procedure), or any material change to this policy pack, our risk assessment, or relevant law.
5. Content sources
Given our size, we do not commission bespoke or paid training content. Sessions draw on free, reputable UK materials, including:
- UK Home Office statutory guidance and modern slavery e-learning resources;
- Unseen UK and the Modern Slavery & Exploitation Helpline materials and indicator guides;
- Gangmasters and Labour Abuse Authority (GLAA) guidance on labour exploitation and licensing standards;
- Our own policy pack (in particular the Anti-Slavery and Human Trafficking Policy's red-flag list and the Ethical Recruitment and Labour Standards Policy), used as the working reference during sessions.
The CRO checks before each annual cycle that these sources remain current and freely available, substituting an equivalent free replacement if one is withdrawn or superseded.
6. Delivery and records
The CRO is responsible for scheduling, delivering (or arranging delivery of), and recording all training under this policy. The CRO maintains a simple training register capturing, for each session:
- Name and role of each attendee;
- Date of the session;
- Content covered (including which source materials were used) and, for role-specific briefings, the specific role the briefing supported.
The register is the CRO's evidence base for two recurring outputs:
- It feeds the CRO's quarterly risk report against the Risk and Control Register, flagging any lapsed or overdue training as an open risk item; and
- It feeds the annual Modern Slavery Statement, which reports the percentage of staff trained in the reporting period as one of our effectiveness metrics.
7. Effectiveness measures
Training is not treated as complete simply because a session took place. For each session, the CRO checks and records:
- Understanding — a short post-session quiz, or a structured group discussion covering the same ground, confirming attendees can name at least two red-flag indicators and identify the reporting channels (the CRO/Modern Slavery Lead, the Whistleblowing and Modern Slavery Reporting Policy channel, and the UK Modern Slavery & Exploitation Helpline);
- Completion — tracked against the training register, with the CRO following up on any missed session or onboarding deadline;
- Coverage — the percentage of current staff trained in the last 12 months, reported to the Board quarterly and in the annual Modern Slavery Statement.
Gaps surfaced by the quiz, discussion, or annual review feed into adjustments to the next session's content.
8. Supplier awareness
Training under this policy covers our own people; supplier-facing awareness is handled separately, through our commercial relationships rather than a training session. Contract managers use contract commencement and renewal negotiations with key suppliers — particularly those in our highest-risk procurement categories (construction and land development, cleaning, catering, promotional goods, and temporary labour) — as an opportunity to brief the supplier on BONDAP's expectations, walk through the Supplier Code of Conduct, and confirm the supplier understands how to raise a concern involving its own workers (see the Supplier Code of Conduct, section 5). This is recorded as part of the standard contract file, not the training register.
9. Responsibility and review
The CRO owns this policy, delivers or arranges all training, maintains the training register, and reports coverage and effectiveness to the Board quarterly and through the annual Modern Slavery Statement. The CEO ensures training time is made available within the business's normal working patterns given our size. The Board of Directors approved this policy, which takes effect on the effective date above, and will review it at least annually, or sooner following any modern slavery incident, a material change to this policy pack, 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.