Modern Slavery & Human Trafficking Statement

1. Our structure#

Boundless Telecom Ltd is a UK private limited company headquartered in England. We operate across the UK and EEA.

2. Supply chain#

Primary supply chain: connectivity (sovereign carrier core), payments (Stripe), cloud (Lovable Cloud / Supabase, Cloudflare), professional services. Secondary: device ODMs and SIM/eSIM manufacturers.

3. Due diligence & risk#

• Supplier onboarding includes Modern Slavery declaration.
• Higher-risk geographies (device manufacturing) require independent third-party audit reports.
• The Supplier Code of Conduct is incorporated into every supplier contract.
• Any concern can be raised confidentially via our Whistleblowing Policy.

4. Training#

All procurement staff complete annual training on identifying modern-slavery red flags. Refresher sessions on case studies are run quarterly.

5. Effectiveness measures#

• Supplier declarations completion: target 100%, reported quarterly.
• Whistleblowing reports received and triaged: reviewed by Audit Committee.
• Modern-slavery incidents detected / remediated.

6. Review & ownership#

Owner: Head of Compliance. Approved annually by the board. Published under section 54 of the Modern Slavery Act 2015.