1. Policy Statement
Boostbery Limited is committed to conducting business ethically, responsibly and with integrity. We have a zero-tolerance approach to all forms of modern slavery, forced labour, bonded labour, human trafficking, servitude and exploitation.
We are committed to ensuring that modern slavery does not occur within our business operations or wider supply chain and we expect the same high standards from all suppliers, contractors, consultants, partners and third parties with whom we work.
Although Boostbery operates primarily as a digital transformation, technology and marketing services provider, we recognise that modern slavery risks can exist within global supply chains and outsourced service arrangements.
This policy supports our commitment to the principles of the Modern Slavery Act 2015 and forms part of our wider ethical, governance and supplier management framework.
2. Scope
This policy applies to directors, employees, contractors, freelancers, agency workers, consultants, suppliers, sub-contractors and business partners. All parties acting on behalf of Boostbery are expected to comply with this policy.
3. Our Commitment
Boostbery is committed to preventing modern slavery and human trafficking, operating ethically and transparently, promoting fair treatment and equal opportunities, ensuring employment is freely chosen, maintaining appropriate controls to identify and manage risk, undertaking proportionate supplier due diligence, working only with suppliers who share our values, investigating concerns promptly and taking corrective action where necessary.
4. Governance & Responsibility
Ultimate responsibility for this policy rests with the Managing Director. Management is responsible for implementing this policy, monitoring compliance, assessing modern slavery risks, reviewing supplier relationships, investigating concerns and reporting material issues where appropriate.
5. Risk Assessment
Boostbery undertakes a risk-based approach to modern slavery. Higher-risk areas may include international supply chains, hardware procurement, technology manufacturing, outsourced labour providers and overseas subcontracting arrangements.
Low Risk Areas
• UK-based professional services
• Digital consultancy
• Marketing services
• Software implementation
• Website development
Higher Risk Areas
• International supply chains
• Hardware procurement
• Technology manufacturing
• Outsourced labour providers
• Facilities management services
• Overseas subcontracting arrangements
Risk assessments are reviewed periodically and whenever significant supplier changes occur.
6. Supplier Due Diligence
Before engaging suppliers, Boostbery may undertake proportionate due diligence which may include:
• Reviewing supplier reputation.
• Reviewing publicly available compliance information.
• Assessing geographic and sector-specific risks.
• Reviewing modern slavery policies where available.
• Confirming compliance with employment legislation.
• Evaluating ethical business practices.
• Assessing previous compliance concerns.
Where risks are identified, additional information may be requested before engagement proceeds.
7. Supplier Expectations
All suppliers are expected to:
• Comply with applicable employment laws.
• Prohibit forced, bonded or involuntary labour.
• Prevent human trafficking.
• Ensure workers are employed voluntarily.
• Provide safe working conditions.
• Pay workers fairly and lawfully.
• Allow concerns to be raised without retaliation.
• Cooperate with any reasonable compliance enquiries.
Boostbery reserves the right to terminate supplier relationships where serious breaches are identified.
8. Ongoing Monitoring
Modern slavery risks are monitored through:
• Periodic supplier reviews.
• Contract renewal reviews.
• Risk-based supplier assessments.
• Monitoring publicly available information.
• Investigation of reported concerns.
• Escalation of identified risks.
Monitoring activity is proportionate to the nature and risk profile of the supplier relationship.
9. Reporting Concerns
Any employee, contractor, supplier or stakeholder who suspects modern slavery or unethical labour practices is encouraged to report concerns immediately. All concerns will be treated seriously and investigated appropriately.
10. Training & Awareness
Boostbery will seek to ensure that relevant personnel understand modern slavery risks, warning signs, supplier due diligence requirements and reporting procedures.
11. Key Performance Indicators (KPIs)
Boostbery may monitor supplier reviews completed, higher-risk suppliers assessed, modern slavery concerns reported, investigations undertaken, staff awareness and corrective actions implemented.
12. Contractual Controls
Where appropriate, Boostbery will seek to include contractual provisions requiring suppliers to comply with modern slavery legislation, maintain policies and procedures, notify Boostbery of concerns and cooperate with reasonable information requests.
13. Breaches
Any breach of this policy will be treated seriously. Boostbery may require corrective action plans, suspend work, escalate concerns to relevant authorities or terminate supplier agreements where appropriate.
14. Continuous Improvement
Boostbery is committed to continually strengthening its approach to identifying, preventing and mitigating modern slavery risks through periodic review of supplier due diligence, risk assessments, reporting mechanisms and contractual protections.
We will periodically review:
• Supplier due diligence processes.
• Risk assessment methodologies.
• Reporting mechanisms.
• Contractual protections.
• Industry best practice guidance.