Introduction
This statement is made on behalf of Bondsmith Group Ltd and its subsidiaries ("Bondsmith", "we", "us") in respect of the financial year ending 31 March 2026. Although Bondsmith does not currently meet the turnover threshold that triggers the mandatory reporting requirement under section 54 of the UK Modern Slavery Act 2015, we have chosen to publish this statement voluntarily. We believe that operating ethically and transparently is simply good business, and we are committed to playing our part in preventing modern slavery and human trafficking.
Bondsmith has zero tolerance towards modern slavery in all its forms, including slavery, servitude, forced or compulsory labour, debt bondage, child labour, and human trafficking.
Our business and supply chain
Bondsmith is a UK-based financial services business. Our operations and supply chain are primarily UK-focused and centre on professional and technology services rather than the manufacturing or labour-intensive sectors typically associated with higher modern slavery risk. Our key third-party relationships include:
- Platform distributors who make our services available to their customers
- Panel banks with whom customer deposits are placed
- Suppliers of technology, professional, and operational services
- Introducers who refer business to us
All of these relationships are managed under our Third Party Oversight framework.
Our policies
We maintain a Modern Slavery Act Policy, owned by our Head of Risk & Compliance, approved by our Audit, Risk & Compliance Committee, and reviewed at least annually. The policy applies to all employees, contractors, and temporary workers, as well as to all third parties engaged by Bondsmith. Our Board holds overall accountability for the effectiveness of our approach.
Due diligence and risk assessment
We take practical steps to identify and manage modern slavery risk across our business relationships:
- During onboarding, we review each third party's published statements to confirm their compliance with the Modern Slavery Act 2015 or, where no public confirmation exists, we obtain written confirmation directly.
- Third-party due diligence explicitly considers modern slavery risk, and we conduct negative news screening that includes checks for modern slavery-related issues.
- Enhanced due diligence is applied to third parties operating in higher-risk sectors or jurisdictions.
- We maintain a third-party risk register and carry out a structured risk assessment of our supply chain at least annually, updating it whenever there are significant changes to suppliers, geographies, or industry risks.
- Where a third party is found to be in breach of our expectations, this is escalated and managed under our Third Party Oversight Policy, and suspected incidents are investigated by our Risk & Compliance team and reported to our Audit, Risk & Compliance Committee.
Our people
We are committed to fair and voluntary employment. Our recruitment processes include identity verification, right-to-work checks, DBS checks, and credit checks, and all employees receive written employment contracts and fair compensation.
Training and awareness
All staff complete mandatory training on modern slavery and human rights risks at induction and annually thereafter. Training covers how to identify potential modern slavery risks, recognise red flags in business relationships, and escalate concerns. Content is refreshed at least annually to reflect regulatory developments, industry trends, and practical case studies relevant to the financial services sector.
Raising concerns
Employees and third parties are encouraged to raise any concerns about modern slavery, without fear of reprisal, by contacting compliance@bondsmith.co.uk or the Head of Risk & Compliance directly. All reports are investigated and escalated as appropriate.
Measuring effectiveness
We monitor the effectiveness of our approach through annual reporting to the Audit, Risk & Compliance Committee on modern slavery risks and controls, tracking of training completion rates, and ongoing monitoring of higher-risk third-party relationships.
Approval
This statement was approved by the Chief Executive Officer of Bondsmith Group Ltd on 1 April 2026.
Michael Doyle, Chief Executive Officer, Bondsmith Group Ltd. 1 April 2026.