Last modified: Version 3.0 December 2025
oboloo is committed to the highest standards of ethical conduct, integrity, and social responsibility across all areas of our business. We recognise our obligation under the UK Modern Slavery Act 2015 to take all reasonable steps to prevent modern slavery, forced labour, and human trafficking within our organisation and throughout our supply chain.
Although oboloo operates as a global Software-as-a-Service (SaaS) provider and is considered low-risk for modern slavery, we take this responsibility seriously and maintain a zero-tolerance approach to any form of exploitation.
This policy outlines the actions oboloo takes to identify, prevent, and respond to risks related to modern slavery.
oboloo Limited is a UK-based SaaS company providing procurement and supplier management software to organisations worldwide. We operate a remote-first workforce, supported by trusted contractors and technology partners internationally. Our supply chain primarily consists of:
- cloud hosting and infrastructure providers
- software vendors and IT service providers
- professional services and consultancy firms
- administrative and operational suppliers
We do not operate any manufacturing, distribution, or physical labour environments.
oboloo is committed to:
- maintaining a zero-tolerance approach to modern slavery and human trafficking
- ensuring ethical conduct in all business relationships
- conducting due diligence on suppliers and contractors
- responding quickly to any concerns or violations
- continuously improving our processes to reduce risk
Responsibility for this policy sits with:
- Board of Directors – oversight, review, and approval
- Senior Leadership Team – implementation and compliance
- Supplier Management Team – due diligence, onboarding, and monitoring
- All Employees & Contractors – reporting concerns and acting ethically
oboloo has several internal and external policies that support our commitment to preventing modern slavery, including:
- Global Supplier Code of Conduct
- Employee Code of Conduct
- Anti-Bribery & Corruption Policy
- Whistleblowing & Speak-Up Policy
- Recruitment & Contractor Onboarding Procedures
- Supplier Onboarding & Risk Assessment Framework
Together, these set clear expectations for behaviour, ethical practice, and compliance.
To mitigate risks in our supply chain, oboloo undertakes the following actions:
1. Supplier Onboarding Assessments- All suppliers undergo a risk-based evaluation prior to onboarding.
- Higher-risk suppliers (e.g., offshore service providers) undergo enhanced checks.
2. Supplier Code of Conduct Acknowledgement
- All suppliers must accept our Supplier Code of Conduct, which includes explicit prohibitions on forced labour and human trafficking.
3. Contractual Controls
- Supplier agreements include compliance obligations and the right to terminate if modern slavery concerns arise.
4. Ongoing Monitoring
- We monitor suppliers for changes in risk, performance, ownership, location, or compliance history.
5. Corrective Action Process
- Any identified issues trigger a corrective action plan.
- Non-compliance may lead to suspension or termination.
oboloo’s internal recruitment practices include:
- verifying candidate identity and legal working status
- paying fair and legal wages
- ensuring no recruitment fees are charged to candidates
- prohibiting any form of bonded labour
- providing clear contracts and working terms
- ensuring contractors and offshore partners follow the same standards
As a remote-first business, we ensure all employment relationships are voluntary and transparent.
We conduct:
- Annual Code of Conduct training for all employees
- Supplier Code training expectations for contracted partners
- Internal awareness on recognising and reporting signs of exploitation
- Additional guidance for teams involved in supplier onboarding or procurement
oboloo encourages employees, contractors, customers, and suppliers to raise concerns relating to suspected modern slavery.
Reports can be made confidentially via:
- internal reporting channels
- our whistleblowing mechanism
- senior leadership or legal representatives
All reports are investigated promptly, with protection against retaliation.
If oboloo identifies or is informed of potential modern slavery:
1. We will conduct an immediate internal review.
2. We will consult with legal advisors.
3. We may request corrective action from the supplier.
4. We may report the issue to the relevant authorities.
5. We may suspend or terminate the supplier relationship.
Our priority is to ensure safety, compliance, and ethical practice.
oboloo is committed to enhancing our modern slavery controls by reviewing:
- supplier assessment criteria
- onboarding and monitoring processes
- escalation paths and corrective actions
- staff and supplier training materials
This policy is reviewed annually and updated as needed.
This Modern Slavery & Human Trafficking Policy applies to oboloo.com and oboloo Limited.
Approved by: The Board of Directors, oboloo Limited
Date: 22nd December 2025