Supplier Due Diligence Procedure and Modern Slavery Questionnaire

1. Purpose and scope

This procedure sets out how BONDAP LTD screens and assesses suppliers for modern slavery risk before they are engaged, and how existing suppliers are brought into the same process over time. It gives practical effect to the commitments in our Modern Slavery Statement and sits under the Risk Management Framework (RMF) owned by the CEO, with quarterly reporting to the Board by the Chief Risk Officer (CRO).

In scope:

• Every new direct supplier, contractor, or subcontractor engaged by BONDAP LTD, of any size, must complete this procedure before contract signature. No purchase order or contract may be issued to a new direct supplier that has not been risk-tiered under section 2.
• Existing suppliers are assessed progressively, prioritised by risk (highest-risk categories and geographies first), because we do not yet hold complete data on our full existing supplier base. The CRO maintains a rolling schedule of existing suppliers still to be assessed and reports progress quarterly to the Board.
• Contract renewal is a mandatory trigger for (re-)assessment: a supplier's tier and evidence must be refreshed at renewal even if no assessment was previously done. High-tier suppliers are additionally re-assessed annually whether or not a renewal falls due (section 3).
• This procedure applies to direct suppliers only at the outset. Sub-tier (Tier 2) suppliers are addressed progressively — see section 6.
• It must be read alongside the Supplier Code of Conduct, the Supply Chain Management Policy, and Model Contract Clauses — Modern Slavery.

Supplier selection itself remains a Board decision, made case-by-case given our size; this procedure governs the modern slavery screening that must happen alongside that selection, not the commercial selection decision itself.

2. Risk-tiering model

Every new or existing supplier is screened on two factors — category and geography — to produce a single overall tier: Low, Medium, or High. The screen should take a few minutes; it is deliberately simple so it actually gets used.

Factor 1 — category risk. The five categories identified as highest-risk in our Modern Slavery Statement are automatically at least Medium, regardless of geography. Temporary labour and recruitment/labour-hire agencies are always High, because of the elevated risk of debt bondage, fee-charging, and controlled workers in that category.

Factor 2 — geography risk. Score the supplier's principal country of operation and, where the work is performed elsewhere, the country where the work is actually performed; where the two differ, the higher band applies. Apply the following ordered test. Each step reads off a published figure, so the contract manager can complete it without further guidance; stop at the first step that applies.

The CRO checks both indices against their current published editions at the time of each assessment, and confirms at each annual review of this procedure that both remain published and freely available, substituting an equivalent published index if either is withdrawn. The banding applied and the index edition used are recorded with the assessment.

Combining the two factors — overall tier:

The higher of the two factors always wins.

The contract manager records the category, geography, expected annual spend, and resulting tier on the supplier's entry in the contracts repository at the point of screening.

3. Due diligence steps by tier

For High-tier suppliers, engagement must not proceed until the CRO has reviewed the questionnaire and the Board has recorded sign-off (by email or minute is sufficient given our size — a full committee process is not required). For Low and Medium tiers, the contract manager may complete and file the assessment without Board sign-off, but any red flag identified (section 4) is escalated regardless of tier.

4. Evaluating questionnaire responses

A response is treated as a red flag where, for example: the supplier cannot confirm who employs the workers on a contract; workers pay a recruitment fee, directly or by deduction from wages; identity documents or passports are held by the employer or an agency; there is no written contract of employment; the supplier cannot confirm minimum wage compliance; subcontracting or agency use is undisclosed or the supplier is unwilling to name subcontractors/agencies used; or the supplier declines to answer, or the answers are inconsistent with a subsequent published statement or public information.

Possible outcomes:

• Approve — no red flags; questionnaire or supplier statement is satisfactory; proceed under the contract clauses for that tier.
• Approve with conditions — one or more red flags, but not sufficient to block engagement, subject to a written improvement plan agreed with the supplier with specific actions and deadlines (e.g. 90 days to produce written contracts of employment; 60 days to confirm minimum wage compliance). No deadline in an improvement plan may exceed 90 days from the date the plan is agreed. The contract manager tracks the improvement plan and reports missed deadlines to the CRO within 5 business days of the deadline passing; the CRO decides whether to extend once (by no more than a further 90 days), escalate, or move the supplier to Reject.
• Reject — red flags indicate a serious or unresolved risk (e.g. evidence of withheld documents, unpaid recruitment fees, or refusal to engage with the process); the supplier is not engaged, or an existing contract is not renewed, without Board sign-off to override.

Any red flag on a High-tier supplier, and any red flag suggesting an actual (not just potential) instance of forced labour, trafficking, or debt bondage at any tier, is escalated immediately to the CRO and, where it may constitute an incident, handled under the Modern Slavery Incident Response and Remediation Procedure rather than resolved through an improvement plan alone.

5. Records

Every assessment — new or renewal — is logged in the contracts repository and, where it identifies a risk requiring monitoring, in the Risk and Control Register under the RMF, recording at minimum: supplier name, category and geography scores, overall tier, named contract manager, date of assessment, outcome (approve / approve with conditions / reject), improvement plan deadlines (if any), and next review date. High-tier suppliers are diarised for annual re-assessment; Medium-tier suppliers are reviewed at renewal; Low-tier suppliers are reviewed at renewal or if their category/geography changes.

The CRO's quarterly report to the Board includes the running count of suppliers assessed (new and existing), the count outstanding, the count of open improvement plans and overdue deadlines, and any rejections or escalations in the period. These figures also feed the metrics reported in the annual Modern Slavery Statement (e.g. proportion of direct suppliers risk-assessed, proportion of high-risk suppliers with a completed questionnaire).

6. Progressive Tier 2 visibility

We do not yet know our Tier 2 (sub-tier) suppliers, the terms of employment used by our contractors, or where recruitment agencies are used across our supply chain. The Modern Slavery Questionnaire (Annex A, section D) specifically asks each direct supplier to disclose its subcontractors and any recruitment or labour-hire agencies it uses, and where those parties operate.

Target: map recruitment-agency use among all existing High-tier (including temporary labour) suppliers within 12 months of this procedure's effective date. The CRO reports progress against this target quarterly to the Board, and any gaps remaining at the 12-month point are reported in the next annual Modern Slavery Statement along with a revised timescale.

7. Governance, review and approval

This procedure is owned by the CRO and forms part of the Risk Management Framework owned by the CEO. 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 a rejected supplier, a modern slavery incident, or a material change to our supply chains. Any material revision requires Board approval.

Annex A — Modern Slavery Questionnaire

To be completed by the supplier and returned to the BONDAP contract manager named on the contract, or sent in place of this questionnaire: a copy of the supplier's own published Modern Slavery Statement covering the relevant entity.

Section A — Supplier details

1. Legal name of supplier and country/countries of registration.
2. Registered address and principal trading address(es).
3. Name, role, and contact details of the person completing this questionnaire.
4. Description of the goods or services to be supplied to BONDAP.
5. Approximate number of workers (employed and contracted) involved in supplying BONDAP.

Section B — Policies

6. Do you have a written anti-slavery / anti-trafficking policy? (Yes/No — attach)
7. Have you published a Modern Slavery Statement under any jurisdiction's modern slavery legislation? (Yes/No — attach or provide link)
8. Do your own suppliers/subcontractors have to meet minimum labour standards as a condition of doing business with you? (Yes/No — Details)

Section C — Workforce

9. Do you use temporary, seasonal, or agency labour? (Yes/No — Details)
10. Do you employ migrant or foreign national workers? (Yes/No — Details of countries/visa routes)
11. Do you employ workers under the age of 18? (Yes/No — Details of safeguards)
12. Who pays any recruitment fees associated with hiring your workers — the worker, you, or a third party? (Details)
13. Do you or your recruitment agencies retain workers' passports or identity documents? (Yes/No — Details)
14. Do all workers have a written contract of employment in a language they understand? (Yes/No — Details)
15. Can you confirm all workers are paid at least the applicable statutory minimum wage, on time, directly to the worker? (Yes/No — Details)
16. Are working hours and rest breaks compliant with applicable law? (Yes/No — Details)

Section D — Supply chain and subcontracting

17. Do you subcontract any part of the goods/services supplied to BONDAP? (Yes/No — Details of subcontractors and countries)
18. Do you use any recruitment or labour-hire agencies to source workers, and if so, which agencies and in which countries? (Yes/No — Details)
19. Do you know the labour practices of your own direct suppliers (your Tier 2, from BONDAP's perspective)? (Yes/No — Details)
20. Do you carry out any modern slavery due diligence on your own suppliers or agencies? (Yes/No — Details)

Section E — Incidents and remediation

21. Have you identified, or been notified of, any actual or suspected case of forced labour, trafficking, or exploitation in your operations or supply chain in the last 3 years? (Yes/No — Details)
22. Do workers have access to a confidential grievance or whistleblowing mechanism, independent of their direct supervisor? (Yes/No — Details)
23. If a case were identified, what would your remediation process be? (Details)

Declaration

I confirm that the information provided in this questionnaire is accurate and complete to the best of my knowledge, and I agree to notify BONDAP LTD promptly if any answer changes materially.

BONDAP internal use: reviewed by [contract manager name] — tier: [Low/Medium/High] — outcome: [approve / approve with conditions / reject] — date: [date] — next review: [date].

© 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.