oboloo Modern Slavery Statement

1Statement

1.1oboloo Limited does not tolerate modern slavery, forced labour, child labour or human trafficking in any part of its business or supply chain. This statement sets out what we do to prevent it.

1.2oboloo is below the £36 million turnover threshold at which the Modern Slavery Act 2015 requires a company to publish a statement. We publish one anyway, for two reasons. Our customers, many of whom are above the threshold, ask us to. And our product exists to help organisations answer the same question about their own suppliers, so we hold ourselves to the standard we help them meet.

1.3This statement is reviewed and republished every year.

2Our organisation

2.1oboloo Limited is a company registered in England and Wales under company number 12420854, with its registered office at 7 Bell Yard, London, WC2A 2JR. We build and operate oboloo, a procurement platform for supplier, sourcing, contract and savings management, used by businesses and charities.

2.2We are a small, remote-first team based in the United Kingdom, supported by specialist contractors. We do not manufacture, distribute or handle goods, and we do not operate any physical labour environments. Our people are employed or engaged directly under written contracts governed by UK law.

3Our supply chains

3.1Our supply chain is short and almost entirely digital and professional. It falls into five categories:

3.2Our sub-processors are listed in Annex 3 of our Data Processing Agreement at oboloo.com/dpa.

4Policies

4.1This statement is supported by our Equality, Diversity and Inclusion Policy, Sustainability Policy, Acceptable Use Policy and Information Security Policy, all published at oboloo.com/data-and-security, and by the following commitments, which apply to everyone who works for or with us:

• Nobody who works for oboloo pays a fee to obtain or keep their work. We do not use recruitment agencies that charge workers.
• Everyone who works for oboloo has a written contract, is paid at least the Real Living Wage, is free to leave on reasonable notice, and keeps their own identity documents.
• We verify identity and right to work before anyone starts.
• Contractors are engaged on the same ethical terms as employees and must confirm that they apply the same standards to anyone they engage on our work.
• Our Affiliate and Referral Partner Agreement and our supplier terms require compliance with the Modern Slavery Act 2015 and the Bribery Act 2010.

5Due diligence

5.1We manage our own suppliers in oboloo, using the same supplier onboarding, document request and scorecard features our customers use. Before we start spending with a new supplier we:

• record who they are, where they operate and what they provide;
• ask suppliers above the £36 million threshold for a link to their published modern slavery statement, and ask smaller suppliers to confirm in our onboarding questionnaire that they do not use forced, bonded or child labour and that their workers are paid lawfully;
• include a modern slavery and anti-bribery clause in our contracts, with a right to terminate for breach;
• rate the supplier's risk using the factors in section 6 and set a review date.

5.2Existing suppliers are reviewed at least annually, and sooner if their ownership, location or the nature of what they provide changes.

5.3Where a supplier cannot give us the assurance we need, we work with them to put it in place within an agreed time. If they cannot or will not, we stop using them.

6Risk assessment

6.1We assess risk by country, sector and the nature of the work. Our overall risk is low: our suppliers are in the United Kingdom, the European Union and the United States, and the services we buy are skilled, salaried or professional work.

6.2The areas we treat as higher risk, and what we do about them, are:

7Training and awareness

7.1Everyone who works for oboloo, including contractors, is briefed on this statement when they join and each year after that. The briefing covers what modern slavery looks like in a digital and professional supply chain, the warning signs in a supplier relationship, and how to raise a concern.

7.2Our free Procurement Foundations course at academy.oboloo.com includes supplier due diligence, and the supplier questionnaire templates in oboloo include modern slavery questions, so our customers can apply the same checks to their own supply chains.

8Measuring effectiveness

8.1We track, and review at least annually:

• the proportion of our active suppliers that have completed onboarding in oboloo, including the modern slavery confirmation;
• the proportion of suppliers above the threshold whose published statement we hold;
• the number of concerns raised under section 9 and how each was resolved;
• completion of the annual briefing under section 7.

8.2Our target is 100% for (a), (b) and (d). Where we fall short, the next version of this statement says so and what we are doing about it.

9Reporting concerns

9.1Anyone, inside or outside oboloo, who suspects modern slavery in our business or supply chain should tell us at support@oboloo.app with the subject line “Modern slavery”. Concerns can be raised anonymously. We investigate every report, keep the reporter informed where we can, and do not tolerate retaliation against anyone who raises a concern in good faith.

9.2If we find modern slavery in our supply chain we act in the interests of the people affected first: we take advice, report to the relevant authorities where appropriate, require the supplier to put matters right, and end the relationship if they do not. The UK Modern Slavery and Exploitation Helpline is available on 08000 121 700 and at modernslaveryhelpline.org.

10Approval and version history

This statement was approved by the Board of Directors of oboloo Limited in October 2026 and is signed on its behalf by a director. It is reviewed and republished annually.