Modern Slavery and Human Trafficking Statement

2. Business Overview and Operating Model

Salibo Ltd is a UK-registered company delivering technology-enabled security, intelligence, and workforce-management solutions. The Company operates across employment, technology, and regulated security environments, including:

1. Managed security services
2. Marketplace-enabled security officer engagement
3. AI-enabled CCTV intelligence and alerting
4. Incident reporting, audit, and compliance systems
5. SaaS security and workforce management platforms

Salibo operates exclusively within the United Kingdom, where labour protections are well established; however, the Company acknowledges that modern slavery risks can arise even in low-risk jurisdictions, particularly through indirect labour supply chains or poorly governed subcontracting models.

3. Legal Capacity Separation and Risk Containment

A foundational principle of Salibo's governance model is explicit legal capacity separation. Depending on the product and engagement, Salibo may act as:

1. A technology platform provider
2. A marketplace facilitator
3. A PAYE employer
4. A managed security services provider
5. A SaaS licensor
6. An AI intelligence and alerting provider

Each capacity carries distinct legal duties, labour responsibilities, and regulatory exposure. No obligation, employment relationship, agency relationship, or duty of care is implied across capacities unless expressly stated in the relevant governing agreement. This separation is critical to:

• a) preventing joint-employer risk
• b) maintaining HMRC and employment-status clarity
• c) ensuring accurate attribution of labour responsibility
• d) preventing ethical and legal ambiguity within supply chains

Modern slavery risk is therefore assessed within the context of each capacity, rather than through a single, aggregated operational lens.

4. Governance, Oversight and Accountability

Ultimate responsibility for modern slavery prevention rests with the Board of Directors of Salibo Ltd. Oversight is exercised through:

1. Board approval and annual review of this Statement
2. Senior management accountability for recruitment, engagement, and supplier governance
3. Integration with Salibo's legal, policy, and governance architecture
4. Alignment with safeguarding, whistleblowing, vetting, and ethical conduct controls

Modern slavery risk is treated as a material governance and reputational risk, reviewed alongside wider ESG, safeguarding, and compliance considerations.

5. Policies Supporting Modern Slavery Prevention

Salibo's zero-tolerance approach to modern slavery is supported by a structured policy framework, including:

1. Modern Slavery and Human Trafficking Policy
2. Recruitment and Vetting Policy (including BS7858 screening)
3. Whistleblowing Policy
4. Officer Code of Conduct
5. Equality, Diversity and Inclusion Policy
6. Safeguarding and Vulnerable Persons Policy
7. Third-Party and Subprocessor Governance Policy
8. Ethical Conduct and Conflicts of Interest Policy

These policies are reviewed regularly, approved at the senior level, and communicated to relevant stakeholders.

6. Operational and Supply Chain Risk Profile

7. Due Diligence and Risk-Based Controls

Salibo applies a proportionate, risk-based approach to modern slavery due diligence. Key controls include:

1. Right-to-work verification in accordance with UK legislation
2. Mandatory BS7858 vetting for all deployed security officers
3. Verification that PAYE staff are paid in accordance with UK employment law and the National Living Wage
4. Contractual anti-slavery clauses in supplier and subcontractor agreements
5. Assessment of labour suppliers' recruitment and payment practices
6. Ongoing monitoring of engagement models and working conditions

Suppliers may be categorised as low, medium, or higher risk based on labour intensity, subcontracting exposure, and operational context. Higher-risk relationships are subject to enhanced scrutiny.

8. Recruitment, Engagement and Worker Protection

Salibo is committed to ensuring that all work is freely chosen and that no forced, bonded, or involuntary labour is used. The Company's recruitment and engagement practices ensure that:

1. No worker is required to pay recruitment or placement fees
2. No worker is required to lodge identity documents
3. Terms of engagement are transparent and communicated in advance
4. Working hours comply with the Working Time Regulations
5. Payment is made directly and transparently
6. Individuals are free to accept or decline work where applicable

Salibo recognises that security work can attract individuals who may be economically vulnerable. Recruitment processes are designed to protect such individuals through fairness, pay transparency, and access to confidential reporting mechanisms.

9. Training and Awareness

Appropriate training and awareness are provided to:

1. Managers involved in recruitment and supplier engagement
2. Staff responsible for procurement and governance
3. Security officers where relevant to their role

Training includes:

• A. Recognising indicators of modern slavery and exploitation
• B. Understanding reporting and escalation pathways
• C. Reinforcing Salibo's zero-tolerance approach

10. Reporting, Escalation and Remediation

Salibo encourages employees, officers, contractors, suppliers, and third parties to report concerns relating to modern slavery without fear of retaliation. Concerns may be raised through:

• A. Line management
• B. The designated Compliance or Safeguarding Lead
• C. Salibo's Whistleblowing Policy

All reports are handled confidentially and investigated promptly. Where credible indicators of modern slavery are identified, Salibo will assess severity and proportionality and may:

• A. Implement corrective action plans
• B. Apply enhanced monitoring
• C. Suspend or terminate relationships
• D. Refer matters to the appropriate authorities where required

11. Monitoring Effectiveness and Continuous Improvement

Salibo monitors the effectiveness of its approach through:

• A. 100% right-to-work verification prior to onboarding
• B. 100% BS7858 vetting for deployed officers
• C. Annual review of recruitment and supplier practices
• D. Monitoring whistleblowing reports and engagement anomalies
• E. Annual Board-level review of modern slavery risk

The Company is committed to continuous improvement as its operations and supply chains evolve.

12. Approval and Publication

This Statement has been approved by the Board of Directors of Salibo Ltd and is published on the Company's website.