Our position
Bondap does not tolerate modern slavery, human trafficking, forced or compulsory labour, or child labour in our own operations or in our supply chain. BONDAP LTD is incorporated in Scotland (Company No. SC649467, registered office 5 South Charlotte Street, Edinburgh EH2 4AN) and controlled from the United Kingdom; it is part of the Bondap group together with BONDAP Sp. z o.o. (Gdańsk, Poland). Our people work in the United Kingdom and in Poland, and we buy a narrow range of goods and services — principally cloud infrastructure, software licences and professional services.
We are not required to publish a statement under section 54 of the Modern Slavery Act 2015 and publish one voluntarily, because we are committed to ensuring that slavery and human trafficking are not taking place in our supply chains or in any part of our business. Our current statement — our first — covers 1 January to 31 December 2025, was approved by the Board of Directors of BONDAP LTD on 2 January 2026 and is signed by the directors. It is made under section 54(1) of the Modern Slavery Act 2015 and also addresses the Australian Modern Slavery Act and the California Transparency in Supply Chains Act.
What we publish
| Item | Where | Covers |
|---|---|---|
| Statement on Modern Slavery | Statement on Modern Slavery 2025 (web page) · PDF | Our structure, business and supply chains; our policies; our risk management framework and Roadmap for Modern Slavery Risk Management; the actions committed for the next reporting period; consultation and approval. Reporting period 1 January – 31 December 2025; approved 2 January 2026. |
| Modern Slavery Policy Pack (eight documents) | Modern Slavery Policy Pack on bondap.com | The policies and procedures that put the statement's commitments into practice: anti-slavery policy, supplier code of conduct, supplier due diligence procedure and questionnaire, ethical recruitment, whistleblowing, incident response, training, and model contract clauses. Version 1.0, approved by the Board, in effect from 1 August 2026, next review 1 August 2027. |
| Carbon Reduction Plan (Cabinet Office PPN 006 template, the 2025 update of PPN 06/21) | Carbon Reduction Plan on bondap.com | Baseline and current-year emissions, our net zero commitment and the carbon reduction projects in place, in the Cabinet Office template. Reporting year 2025; published September 2026. |
| Modern Slavery Assessment Tool (MSAT) | Cabinet Office platform — available to public-sector buyers on request | Our completed supplier return, covering organisational commitment, due diligence, risk assessment and remediation. Completed 26 August 2026; the return and its result are visible to public-sector buyers on the platform. |
Our policies
The commitments in our Statement on Modern Slavery are delivered by our Modern Slavery Policy Pack, approved by the Board of Directors and in effect from 1 August 2026. It applies to BONDAP LTD and, once adopted by its management board, to BONDAP Sp. z o.o. Each document is owned by the Chief Risk Officer, who is our Modern Slavery Lead, and is reviewed at least annually.
| Document | What it does |
|---|---|
| Anti-Slavery and Human Trafficking Policy | Our zero-tolerance position, the risk areas specific to our business, the red-flag indicators staff must recognise, and the duty and routes to report a concern. |
| Supplier Code of Conduct | The labour and human-rights standards every supplier, subcontractor, agency and labour provider must meet, flowing down to their own supply chains: no forced or child labour, no worker-paid recruitment fees, workers keep their own identity documents, written contracts, lawful pay and hours. |
| Supplier Due Diligence Procedure and Modern Slavery Questionnaire | How suppliers are risk-tiered before engagement and at renewal, the due diligence required at each tier, and the questionnaire suppliers complete. |
| Ethical Recruitment and Labour Standards Policy | Right-to-work checks, written terms, pay direct to the worker, no recruitment fees or deposits, extra checks for workers at higher risk, and vetting of any recruitment agency before use. |
| Whistleblowing and Modern Slavery Reporting Policy | Who can report, the internal, anonymous and external routes, confidentiality, and the guarantee of no retaliation. |
| Modern Slavery Incident Response and Remediation Procedure | Victim-first handling of any suspected incident, from immediate safety through investigation and remediation to responsible exit. |
| Modern Slavery Training and Awareness Policy | Who is trained, to what depth and how often, and how effectiveness is checked. |
| Model Contract Clauses — Modern Slavery | The clauses used in supplier, subcontractor and consultancy contracts, by risk tier. |
The pack sits alongside the policies already published in our statement, which continue to apply: Supply Chain Management (how suppliers are selected, contracted and reviewed, with selection managed by the Board case by case), Workforce Matters, Diversity and Equality, Complaints Policy and Procedure, Work Health and Safety, and Social Value.
Governance is as set out in our statement: a risk management framework owned by the CEO, quarterly reporting by the Chief Risk Officer to the Board against a Risk and Control Register, and an internal Roadmap for Modern Slavery Risk Management. The statement committed us, for the 2026 reporting period, to a dedicated modern slavery policy, awareness training for relevant personnel, a supplier modern slavery questionnaire or review of suppliers' own statements, and a supplier risk assessment for newly engaged direct suppliers. All four are now in place through the policy pack: the policy is adopted; the training programme is adopted and being delivered during the 2026 reporting period; the questionnaire is in use for new and renewing suppliers and is being issued to current higher-risk suppliers; and every new direct supplier is risk-tiered before contract signature.
How we assess our supply chain
Our supply chain is short and low-risk, and we assess it accordingly.
Infrastructure sub-processors. The service runs on two compute and hosting providers with a separate object-storage provider, in the United Kingdom or the EEA according to the customer's selected hosting location (UK-only, EEA-only, or UK/EEA on request); a further provider supplies edge protection only. Their identities are given to customers in the Data Processing Agreement. These are large, regulated providers that publish their own modern slavery statements and supplier standards.
Our own people. Development, engineering and second-line support are provided by Bondap staff in the United Kingdom and by our group development and support resource in Poland, an EEA member state with the labour-law protections that entails. That resource is engaged through BONDAP Sp. z o.o. (Gdańsk), the Polish member of the Bondap group, under Polish employment law.
Screening. All staff and contractors are subject to pre-employment screening in line with the Baseline Personnel Security Standard (BPSS) before any system access is granted. Right-to-work checking is the same control that detects an exploited or trafficked worker, so it is applied without exception. Personnel security is governed by our ISO/IEC 27001:2022 ISMS and by the CSA Cloud Controls Matrix v4.0.2 (CSA STAR Level 1 self-assessment, published on the CSA STAR Registry), whose Human Resources domain covers background screening and the joiners, movers and leavers process.
Risk-tiering and due diligence. Every new direct supplier is screened before contract signature, and every existing supplier at renewal, on category and geography to a Low, Medium or High tier. Construction, cleaning, catering, promotional goods and temporary labour are treated as higher risk, and temporary labour and recruitment agencies always as High. Every supplier acknowledges the Supplier Code of Conduct and accepts our modern slavery contract clauses; Medium and High tier suppliers also complete our Modern Slavery Questionnaire or provide their own published statement; High tier suppliers are signed off by the Board and re-assessed annually.
Supplier standards. As set out in our published social value commitments, we apply supplier standards on ethics, anti-corruption and labour rights, and on health and safety and social responsibility. We also screen against the UK Sanctions List and the OFSI consolidated list.
Training and raising a concern
Security and data protection training is mandatory for all staff at induction and annually thereafter. Modern slavery awareness training is set by our Training and Awareness Policy: an annual session for all staff and regular contractors, a deeper briefing for directors and for anyone with procurement, contracting or recruitment responsibilities, and training for new joiners within 30 days of starting. It is being delivered during the 2026 reporting period.
Anyone — our staff, a contractor, a supplier's personnel or a customer — can raise a concern about modern slavery, labour exploitation or unethical conduct in our operations or supply chain, in confidence, under our Whistleblowing and Modern Slavery Reporting Policy:
- Email speakup@bondap.com. The mailbox is monitored by the Chief Risk Officer, our Modern Slavery Lead, and by a second director. If the concern is about the Chief Risk Officer, contact any other director.
- Anonymously: email speakup@bondap.com from an account that does not identify you, or write to "CRO — Private & Confidential", BONDAP LTD, 5 South Charlotte Street, Edinburgh EH2 4AN.
- Externally: the Modern Slavery & Exploitation Helpline on 08000 121 700 (free, confidential, 24 hours), Crimestoppers on 0800 555 111 (anonymous), or the Gangmasters and Labour Abuse Authority for labour exploitation in a regulated sector.
- If anyone is in immediate danger, call 999 first.
We acknowledge reports within 3 business days where a contact route is given. No one who raises a concern in good faith will suffer detriment, and that applies equally to a supplier's workers. Suspected incidents are handled under our Incident Response and Remediation Procedure, with the safety of affected workers put before commercial interests.
Social value
This page supports three of our published social value themes. Under Tackling economic inequality, we publish that we are a woman-owned and led company using anonymised recruitment, that we run a free remote training programme leading to a job offer for successful participants and open to the unemployed and to disadvantaged groups, that we monitor pay for inequality by gender and race, and that we apply supplier standards on ethics, anti-corruption and labour rights. Under Equal opportunity, we publish training and employment opportunities for disabled people, including training leading to recognised qualifications. Under Wellbeing, we publish investment in staff health, safety and working conditions including regular DSE assessments, a stated management and worker health and safety commitment, and supplier standards on health and safety and social responsibility.
Questions: gc@bondap.com · To raise a concern: speakup@bondap.com
© 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.