Modern Slavery Incident Response and Remediation Procedure

1. Purpose and trigger

This procedure sets out, step by step, what BONDAP does once a report or discovery of suspected modern slavery is on the table. It is the practical mechanism behind the commitment in our Modern Slavery Statement: "In the event an incident is brought to BONDAP's attention, the management team would assess the nature and scale of the incident and engage with the appropriate parties to clarify and seek to remediate the issue."

Trigger: any report or discovery of suspected modern slavery, however it arises — a report under the Whistleblowing and Modern Slavery Reporting Policy, a red flag noticed by staff under the Anti-Slavery and Human Trafficking Policy, a supplier's own notification under the Model Contract Clauses — Modern Slavery, a review under the Supplier Due Diligence Procedure and Modern Slavery Questionnaire, a client or media report, or information from a regulator or the police.

2. Guiding principle

Victim safety and wellbeing come before commercial interests. We do not summarily cut ties with a supplier or subcontractor where doing so would leave affected workers worse off — unpaid, undocumented, or without support. Termination is a last resort used where remediation fails, is refused, or safety requires it (see Step 5), not a default first reaction. Every step below is applied proportionately: at our size (fewer than 10 employees), the "case team" is two people — the CRO plus one director — not a standing committee.

3. Step 1 — Immediate safety

• Within 24 hours of the trigger, the CRO (or whoever first receives the report, escalating immediately to the CRO) makes an initial assessment of whether anyone is in imminent danger.
• If anyone is in immediate danger, call 999 (or the local emergency equivalent) without delay. This step overrides everything else in this procedure.
• Never confront a suspected perpetrator directly. Doing so can endanger victims, tip off those responsible, and destroy evidence needed for a prosecution or NRM referral.
• Never alert the supplier before considering victim safety. Notifying a supplier's management too early, before it is clear whether that management is itself implicated, can prompt evidence destruction, victim intimidation, or workers being moved or hidden.
• If there is no imminent danger, proceed to Step 2 within the same 24-hour window.

4. Step 2 — Triage and case team

• The case team is the CRO plus one non-conflicted director, appointed by the CRO. If the CRO is implicated or conflicted, the CEO leads in the CRO's place, paired with an external adviser appointed by the Board; if both the CRO and the CEO are conflicted, the Board appoints an external adviser to lead alongside the less-conflicted of the two, or two external advisers if neither can take part. Anyone implicated in, or conflicted regarding, the matter steps aside from the case team entirely.
• The case team opens a confidential case record (see the Annex template) with a unique case reference, and logs it in the CRO's incident log referenced in the Whistleblowing and Modern Slavery Reporting Policy.
• The case team classifies the matter to shape the response:
  • Within our own workforce — BONDAP LTD or BONDAP Sp. z o.o. staff, contractors, or agency workers;
  • Direct supplier — a supplier or subcontractor BONDAP contracts with directly;
  • Deeper in the supply chain — a sub-subcontractor, labour agency, or entity not directly contracted by BONDAP but connected via a supplier;
  • Unrelated — outside BONDAP's operations or supply chain (e.g. a general public report with no BONDAP connection); logged, and referred by the CRO to the police — or to the GLAA where it concerns labour exploitation in a GLAA-licensed sector — with the referral recorded before the case is closed as unrelated.

5. Step 3 — Investigation

• The case team must reach initial findings within 10 business days of the case being opened. Where the case team has requested information from a supplier, the supplier has 10 business days to respond under Tier B clause 5.1, so the findings deadline becomes 5 business days after that response is due (or is received, if earlier). Where findings are not achievable even then, the case team records why in the case file and reports a revised date to the Board before the deadline expires. This is a proportionate fact-finding exercise, not a criminal investigation — BONDAP is not a law enforcement body and does not attempt to substitute for one.
• Typical steps: gather the facts already available (the original report, any documents, prior audit or due diligence records); where safe to do so and once initial safety considerations (Step 1) are satisfied, engage the supplier's management to seek clarification; request relevant records or evidence.
• Where the matter involves a supplier on Tier B terms, the case team uses the audit and information rights in the Model Contract Clauses — Modern Slavery (Tier B, clause 5) to request information and, if needed, to audit relevant records or premises. For a supplier on Tier A terms, the case team requests the same information under the supplier's Code of Conduct obligations (Supplier Code of Conduct, sections 3 and 4), and treats refusal as a red flag that moves the supplier to a higher tier and triggers Tier B terms at the next renewal.
• Findings and the evidence relied on are recorded in the case file. If findings are inconclusive, the case team documents what was checked and either closes the case, keeps it open pending further information, or escalates to the Board for direction.

6. Step 4 — Remediation

Remediation is victim-centred and proportionate to what is actually confirmed:

• Support for affected workers — ensure the worker(s) have access to the UK Modern Slavery & Exploitation Helpline (08000 121 700) and other support services; where a worker may be a victim of trafficking or modern slavery, BONDAP supports a National Referral Mechanism (NRM) referral via the police or another first responder organisation. BONDAP is not itself an NRM first responder and cannot make a referral. For an adult potential victim, a referral can only be made with that person's informed consent, so our role is to explain the options, offer support, and pass the matter to a first responder where the person agrees (a child does not need to consent, and a concern about a child is passed on regardless).
• Supplier corrective action plan — where a supplier or subcontractor is implicated, require a written corrective action plan with named owners and deadlines, in line with clause 7 of the Model Contract Clauses — Modern Slavery (Tier B) (10 business days to submit a plan following a request).
• Repayment of worker-paid fees — where workers have paid recruitment, placement, or visa fees prohibited under clause 4 of the Model Contract Clauses — Modern Slavery (Tier B), require the supplier to reimburse those fees to the affected workers within 30 days, and verify with evidence that this has happened.
• Monitoring — the case team tracks completion of the corrective action plan against its deadlines, requesting evidence of completion, and does not close the case until remediation is verified or a decision is made to escalate under Step 5.

7. Step 5 — Escalation and exit

• Where a supplier refuses to engage with remediation, or fails to cure a confirmed breach within the agreed timescale, the case team brings the matter to the Board with a recommendation.
• The Board decides whether to suspend or terminate the contract, using the termination rights in the Model Contract Clauses — Modern Slavery (Tier A clause 3; Tier B clause 8).
• Exit is a last resort: the Board weighs the effect of termination on any affected workers (e.g. would it leave them unpaid or without income while a referral or investigation is ongoing) alongside the need to stop BONDAP funding continued exploitation, and documents that balancing in the case file.

8. Step 6 — Cooperation with authorities

• BONDAP cooperates fully with the police, the GLAA, and other relevant authorities investigating a modern slavery matter connected to our business.
• The case team preserves evidence (documents, correspondence, records) from the point a case is opened and does not delete or alter it.
• Legal advice is taken before making any external statement about a case — to the media, a client, or the public — to avoid prejudicing a criminal investigation or victim safety.
• Although the statutory duty to notify the Secretary of State under MSA 2015 s.52 applies to public authorities and not to BONDAP, we cooperate with any request for information from public authorities as if that spirit of transparency applied to us.

9. Step 7 — Close-out and learning

• On completion (remediation verified, or the case closed as unfounded, unrelated, or escalated to exit), the case team prepares a case report for the Board, summarising what happened, what was done, and the outcome.
• The Risk and Control Register is updated to reflect any change in residual risk, and the Supplier Due Diligence Procedure and Modern Slavery Questionnaire tiering for the supplier concerned (if any) is reviewed and adjusted.
• Anonymised incident metrics (e.g. number of reports received, number escalated to case status, number remediated, number resulting in supplier exit) are disclosed in BONDAP's next annual Modern Slavery Statement, without identifying individuals or, where sensitivity requires, specific suppliers.

10. Governance

This procedure is owned by the CRO, sits within the Risk Management Framework owned by the CEO, and was approved by the Board of Directors, taking effect on the effective date above. It is reviewed at least annually, and always after any case that reveals a gap in the process, or a relevant change in law.

Annex — Incident record template

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