Statement on Modern Slavery 2025

Introduction

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “MSA”) and constitutes the slavery and human trafficking statement of BONDAP LTD.

This statement addresses the period from 1 January 2025 to 31 December 2025, in compliance with the requirements of the United Kingdom Modern Slavery Act, the Australian Modern Slavery Act and the California Transparency in Supply Chains Act.

Metrics contained herein cover 2025 activities, unless otherwise indicated. This statement excludes any entity that elects to report independently. Accordingly, this is not a joint statement covering more than one reporting entity.

This is our first published statement. The company does not yet meet the threshold for mandatory reporting, but we have decided to publish a statement because we are committed to improving our practices to combat slavery and human trafficking, and to ensuring that slavery and human trafficking are not taking place in our supply chains or in any part of our business.

BONDAP’s registered office is located at 5 South Charlotte Street, Edinburgh, EH2 4AN. While it primarily operates in the UK, BONDAP also provides services to customers located elsewhere in the UK and overseas.

Our Business

BONDAP is a technology consulting company supplying turn-key computing solutions and developing its own web-based applications based on the latest technology, together with providing superior customer support and training to take a client’s infrastructure into the future and beyond.

The company currently provides SaaS (software as a service) business solutions — fully hosted, maintained and supported — in a number of areas, including but not limited to:

• B-SAFE. A health and safety case management system for controlling and investigating incidents, carrying out risk assessments, performing audits and inspections, and providing extensive reporting and analysis.
• B-CRM. A customer relationship management system for handling complaints and feedback, subject access requests and other information enquiries.
• Freibaum. An easy-to-use support system for construction businesses. This web-based application supports the entire building lifecycle, from request and conception through construction to facility management. The suite supports the needs of small contractors by offering online collaboration, digital take-off, estimating, and project and property management, all presented in a format that is easy to understand and use.
• Hovix. A system (with consulting and set-up services) for providing automated hosting services on the customer’s own servers. It suits firms planning to run their own hosting, whether commercially (to sell hosting services) or internally (for example, large groups that want their branches to host and manage websites on the group’s own infrastructure).

BONDAP also offers e-commerce solutions, web hosting, web development, remote help desk support, customer training and systems support.

By utilising state-of-the-art equipment and providing the necessary technical expertise, BONDAP brings a fresh perspective on technology consulting to the market.

BONDAP works on the international market. We have clients in the UK, Japan, Vietnam, Australia, Italy, Germany, Hong Kong and elsewhere. We are a highly professional team and provide consulting and outsourcing for many IT companies. We also provide services to universities, laboratories and other education and science-related organisations, governments, legislative bodies and councils.

With operations and supply chains spanning the globe, we are committed to improving the working conditions of people who are connected to our business, and we recognise the need to monitor for conditions that put workers at risk of modern slavery.

Our Organisation’s Structure

BONDAP LTD is a micro-company with fewer than 10 employees. It is a private limited company and part of the BONDAP consortium. The BONDAP consortium comprises BONDAP LTD (Edinburgh, UK) and Bondap Sp. z o.o. (Gdańsk, Poland) and aims to serve customers around the world and enterprises of all sizes — including start-ups, government agencies and academic institutions — through our SaaS platforms, which are comprehensive and broadly adopted.

Our Supply Chains

Our direct supply chain consists of goods and services provided by suppliers that support our provision of products and services, facilities, events and functions. Suppliers have been contracted in key areas including:

• software;
• IT consulting services;
• IT hardware, telecoms/internet and cloud services;
• education services;
• information subscription services;
• research and consulting services;
• building management services;
• other professional services;
• catering;
• events;
• sponsorship and advertising;
• business and trading services;
• publishing; and
• investment and banking services.

Our main supply chains are:

• information technology equipment and services;
• business and trading services; and
• professional services.

Within these categories, we believe the following types of goods and services contract are likely to carry the highest risks in relation to modern slavery and human trafficking:

• construction and land development;
• cleaning;
• catering;
• promotional goods; and
• temporary labour.

While modern slavery can be found among any population, we recognise that certain groups are particularly vulnerable, including:

• domestic and foreign migrant workers;
• contract, agency and temporary workers;
• vulnerable populations (e.g. refugees); and
• young or student workers.

We do not yet know the names of our Tier 2 suppliers, the terms of employment of contractors (e.g. selling partners, suppliers, and goods and services providers), or where recruitment agencies are used.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

This commitment is supported by existing policies as well as changes to our processes, with a view to taking appropriate steps to address, if required, and prevent modern slavery in connection with our own operations, as well as the suppliers who work with us.

What we are doing now

We are implementing a robust risk management framework (“RMF”): the totality of systems, structures, policies and processes in place to identify, assess, mitigate and monitor internal and external sources of risk that could have a material impact on BONDAP’s operations.

Responsibility for implementing the RMF and managing BONDAP’s risks resides with the CEO, members of the senior management group and other identified “risk owners”.

The Chief Risk Officer will prepare a quarterly report on the management of material risks, having regard to a detailed Risk and Control Register that outlines the key risks falling within material risk categories, their consequences, risk indicators, mitigating controls, and additional risk monitoring and management activities. Risk mitigation plans in respect of modern slavery risks will form part of BONDAP’s RMF, and it is currently intended that these plans and actions to improve our management of modern slavery risks will be periodically considered by the Board as part of its oversight of our risk management activities.

BONDAP also has policies in place that apply to the procurement of goods and services, as well as policies on recruitment, ethical standards and the conduct of personnel, which apply to our officers, employees and contractors, such as:

• Social Value
• Supply Chain Management
• Workforce Matters
• Diversity and Equality Policy
• Complaints Policy and Procedure
• Work Health and Safety Policy

We intend to leverage these policies and procedures to improve awareness, identification and reporting mechanisms to manage modern slavery risks. We will also work to develop a modern slavery policy during the next reporting periods.

In addition, we recognise the opportunity to use our supplier negotiations as a channel to build awareness of modern slavery risks, as well as our expectations regarding how they are managed in our supply chain. These negotiations occur at the commencement of the contract and, to a lesser extent, on renewal.

The selection of suppliers by BONDAP is initially managed by the Board of Directors on a case-by-case basis. We are planning to implement a modern slavery questionnaire for a formal response by suppliers, or a review of the supplier’s modern slavery statement (if available), in the next reporting period.

BONDAP is not aware, and has not received any reports, of incidents of modern slavery in our operations or supply chain during the reporting period. In the event that 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.

We are also in the process of implementing a suitable contracts repository software solution. The repository will include functionality to identify risk types, including modern slavery. It will also identify the BONDAP contract manager and the contract manager’s responsibilities for identifying, managing and mitigating risks.

Actions we commit to taking by the end of our next reporting period

• Beginning implementation of the internal Roadmap for Modern Slavery Risk Management.
• Considering how current policies and processes could be strengthened to include modern slavery considerations.
• Conducting awareness training sessions on modern slavery for relevant personnel.
• Undertaking a supplier risk assessment for newly engaged direct suppliers of BONDAP. Due to limitations in existing supplier data, a risk analysis of existing suppliers will initially cover only a portion of the total number of direct suppliers.
• Implementation of the RMS.
• Implementation of the modern slavery questionnaire.

These actions will allow BONDAP to make continual progress in ensuring the effective management of modern slavery risks.

Evaluation of the Effectiveness of Our Actions

While BONDAP is in the early stages of developing its approach to managing this important issue within our own organisation and supply chain, we commenced our activities from a strong starting point and developed an internal Roadmap for Modern Slavery Risk Management to guide our organisation through the set-up and delivery of key actions and milestones to effectively address modern slavery risks. The Roadmap is a working document that may change as our frameworks develop. It sets out actions in relation to internal processes and controls, as well as a process of review, assessment and continual improvement.

Consultation with Our Internal Stakeholders

BONDAP’s approach to managing modern slavery risks for this reporting period has been developed in consultation with key stakeholders across our organisation, to determine a broad-based set of actions to manage modern slavery risks. Internal stakeholders were consulted during the drafting of this statement and were given the opportunity to review and provide feedback at several stages of the process.

© 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.