Spinbox Limited 

Introduction - At Spinbox Limited, a leading software and web agency based in the UK, we are committed to ensuring that all aspects of our business and supply chain are free from slavery and human trafficking. Our commitment to ethical business practices is foundational to our corporate responsibility strategy, and we are dedicated to implementing and enforcing systems and controls to safeguard against any form of modern slavery in our operations. 

Organisational Structure - Spinbox Limited is headquartered in the UK, with business activities primarily centred on providing software development and web services to a diverse clientele. We operate primarily in the UK but have a network of partners and suppliers both domestically and internationally. 

Our Supply Chains - Our supply chain includes procurement of software tools, hardware, and subcontracting services from various global and local providers. We work closely with our partners to ensure alignment with our ethical standards. 

Policies on Slavery and Human Trafficking - We have established a Modern Slavery Policy that reflects our commitment to acting ethically and with integrity in all our business relationships. Furthermore, our Employee Code of Conduct and Supplier Code of Conduct encapsulate the same values, ensuring all stakeholders understand and implement our standards against slavery and human trafficking. 

Due Diligence Processes - To identify and mitigate risk, we have in place: 

  • Rigorous vetting and investigation of our supply chain. 

  • Regular audits of suppliers and partners. 

  • Training for our procurement team on risks related to modern slavery and human trafficking. 

Risk Assessment and Management - Through our risk management procedures, we assess the potential for slavery and human trafficking in our supply chains and implement stringent measures to mitigate these risks. This includes ongoing review of our suppliers and strict compliance requirements for partnering with our business. 

Effectiveness of Our Efforts - We measure the effectiveness of our efforts to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains by: 

  • Regularly reviewing supplier compliance through audits and assessments. 

  • Feedback mechanisms for employees to report unethical practices without fear of retaliation. 

  • Continuous improvement of our policies and procedures. 

Training and Capacity Building - All staff, particularly those involved in supply chain management and procurement, receive training on the implications of the Modern Slavery Act 2015, and on how to identify and respond to indications of slavery and human trafficking. 

Board Approval - This statement has been approved by the Board of Directors of Spinbox Limited and will be reviewed and updated annually. It is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2024. 

Rehan Butt 

Spinbox Limited 
Updated 1st April 2024