Bango PLC Modern Slavery Statement

Introduction

Bango is committed to trading ethically and sourcing responsibly. We have a zero tolerance to slavery and human trafficking. This statement highlights the key activities undertaken during the last financial year (FY2023) to combat modern slavery and human trafficking in our business and supply chain.

The Bango business, organizational structure & supply chains

Bango technology brings together content providers with telcos to create the world’s biggest subscriptions bundling marketplace, giving consumers the content they want in the way they want it. The Bango Digital Vending Machine® (DVM) makes it easy for subscription services to be offered as bundles.

Bango is headquartered in Cambridge, UK and has about 240 employees globally.

Bango products are almost exclusively designed, produced and delivered internally. Bango therefore engages with a very limited number of external providers to support its business operations. Bango external providers are mainly tech companies, and all operate in accordance with the highest industry standards.

Bango’s supply chain does not include any areas identified as being at high risk of modern slavery or human trafficking. Nonetheless, Bango remains vigilant and within 2023 revised and refined the assessment criteria and procedures for new service providers.

Bango policies and actions targeting slavery and human trafficking

Policies

To mitigate the potential risk of modern slavery and human trafficking, Bango has adopted, maintains and actively implements the following:

Anti-Slavery Policy
Bango Anti-Corruption and Bribery Policy
Bango Gifts and Hospitality Policy
Bango Whistleblowing Policy
Employer Equal Opportunity Policy
Health and Safety Policy
Employee Grievance Policy
Salary & Benefits Policy

Wider actions

In addition, Bango has implemented various additional measures to protect against modern slavery and human trafficking, including:

The incorporation of modern slavery and human trafficking considerations within its enterprise risk management framework and associated regular risk
The Legal / Compliance team retains oversight of Bango compliance with modern slavery and human trafficking requirements across the business.
Board oversight of the measures taken to combat slavery and human
Implementation of measures to protect whistle
Incorporation of specific clauses addressing modern slavery and human trafficking in contracts with suppliers, customers and

Bango employees

Given its limited number of suppliers, the most important area of focus for Bango from a modern slavery and human trafficking perspective is its employees. Bango is committed to ethical employment practices and strong employee engagement. The People team has implemented a number of processes and measures to protect the interests and wellbeing of employees including:

Right to Work

As part of Bango zero-tolerance approach to slavery and human trafficking, our People Team conducts rigorous pre- employment checks to ensure all prospective staff have the legal right to work in the UK or other relevant countries and meet the legal age requirements for employment.

Fair Compensation

We ensure that all employees are compensated fairly, with salaries set at no less than the national living wage where applicable or according to market standards based on the role and level of seniority. This ensures equitable and competitive remuneration across all positions.

Employment Terms and Conditions

The standard terms and conditions of employment for Bango employees are drafted in compliance with all applicable laws and reviewed regularly to ensure they are kept up to date with the latest legal and regulatory requirements, and best practice. These terms include provisions that allow employees to terminate their employment at any time, with appropriate notice, ensuring freedom of movement within their careers.

Health and Safety

Bango is committed to the health and safety of all who are involved in or affected by its operations. We comply with all applicable laws and regulations, assess the risks inherent in our activities and implement relevant control measures to minimize potential harm to the heath, safety and welfare of employees and the public.

Employee Wellbeing

Bango is dedicated to supporting the wellbeing of its employees. We offer comprehensive mental health support and a variety of private medical care options tailored to meet the specific requirements of each country where we operate. This commitment to health and wellbeing is a cornerstone of our employment practices, reflecting our dedication to promoting a supportive and ethical workplace environment.

Annual employee engagement survey

Each year, a comprehensive, externally managed employee engagement survey measures employee engagement. The survey is an invaluable resource which allows employees to provide direct, detailed feedback, and helps ensure Bango maintains its inclusive, innovative and stimulating company culture. It is an invaluable way to collect feedback across the entire business and identify measures for improvement

Next steps

Following a review of the effectiveness of the steps taken this year to minimize the risk of slavery or human trafficking in our supply chains, it is clear that the risk of modern slavery and human trafficking at Bango is very low. This is expected to be the same in the 2024 financial year.

Looking ahead over the next year, Bango intends to supplement the measures outlined within this statement by providing all Bango workers with training, particularly those involved in dealing with and selecting suppliers through the procurement process. All Bango policies are reviewed annually, and the Compliance function reviews existing policies, systems and processes at least annually, ensuring updates and/or additional processes and policies are implemented as appropriate.

This statement is prepared and published in accordance with section 54 of the Modern Slavery Act 2015 and constitutes Bango group’s slavery and human trafficking statement. It is made in relation to the financial year ending December 31st, 2023 and was approved by the board on Sept. 20, 2024.

PAUL LARBEY, CEO

BANGO PLC