Modern Slavery and Human Trafficking Statement
1) Overview
This Modern Slavery & Human Trafficking Statement (“Statement”) sets out the steps taken by Caribou Digital (UK) Limited and its subsidiaries and affiliates (together, “Caribou”) to prevent modern slavery and human trafficking in our business and supply chains. Although Caribou currently does not meet the turnover threshold requiring a statement under Section 54 of the UK Modern Slavery Act 2015, we voluntarily publish this Statement to promote transparency and accountability.
2) Our business & supply chains
Caribou is a remote-first professional services consultancy working worldwide with clients, partners, and grantees. Our supply chains are primarily people-based services (specialist consultants, research partners, facilitators), professional services, and cloud software/services. We also engage delivery partners and grantees on programmes we administer. While risk is lower than goods manufacturing, modern slavery can occur in any country or sector; we apply proportionate controls across engagements.
3) Our policies & governance (public documents)
We maintain a zero-tolerance approach to modern slavery and human trafficking. Our commitment is supported by these public policies:
- Supplier Code of Conduct (labour & human-rights standards, Speak Up, flow-down)
- Whistleblowing (Speak Up) Policy (confidential channel: cariboudigital.ethicspoint.com, non-retaliation)
- Anti-Bribery & Anti-Corruption Policy
- Safeguarding Policy
- Conflicts of Interest Policy
- Privacy Notice
- Corporate Social Responsibility Statement
Day-to-day responsibility sits with management; overall accountability rests with the Executive Leadership Team (ELT) and CEO.
4) Risk assessment & higher-risk areas
We use a risk-based approach, focusing where likelihood/impact are higher, including:
- Fieldwork and research in higher-risk countries/contexts;
- Subcontracted services (enumerators, community partners, logistics);
- Events/travel arranged via local partners;
- Grant-making where funds flow to third-parties.
5) Due diligence & supplier/partner standards
- Contractual commitments & flow-down: the Supplier Code of Conduct is incorporated into contracts; suppliers must apply equivalent standards to their subcontractors.
- Prohibited practices: no forced, bonded, involuntary, or child labour; no recruitment fees charged to workers; fair wages, hours, and working conditions.
- Onboarding checks (risk-based): information on labour practices, ownership, and relevant policies; consideration of country/context risk and engagement nature.
- Programme safeguards: grantees/partners must notify Caribou promptly of material safeguarding or labour-rights incidents linked to Caribou-funded work; survivors’ confidentiality is respected.
- Speak Up: any person (including supplier personnel and participants) can raise concerns confidentially via EthicsPoint; retaliation is prohibited.
- Remediation: we work with suppliers/partners on corrective actions proportionate to risk; serious or unremedied breaches may lead to suspension or termination and, where required, reporting to authorities.
6) Reporting concerns
Concerns can be raised confidentially (and, where lawful, anonymously) via cariboudigital.ethicspoint.com. We prohibit retaliation against good-faith reporters. You may also contact hello@caribou.global.
This Statement was approved by the Board of Directors of Caribou Digital (UK) Limited and signed on its behalf by the Chief Executive Officer.