Modern Slavery & Human Trafficking Policy

1. Purpose

This policy demonstrates SuperSubBetting's commitment to preventing modern slavery and human trafficking in its operations and supply chain. It is published as best practice, even though the statutory transparency reporting obligation under section 54 of the Modern Slavery Act 2015 applies only to organisations with an annual turnover of £36 million or more — a threshold that this business does not meet.

2. Legal context

Legal requirement: The section 54 transparency-in-supply-chains statement requirement under the Modern Slavery Act 2015 does not apply to SuperSubBetting because its annual turnover is below the £36 million threshold.

Why this policy still exists: Publishing it documents the business's zero-tolerance commitment and the checks applied to suppliers and commercial counterparties.

3. Scope

This policy applies to all activities of SuperSubBetting, including:

• Any contracted individuals or freelancers engaged in content creation, development or marketing.
• Digital service providers (hosting, analytics, tools).
• Operators and other businesses with whom SuperSubBetting has commercial relationships.

4. Our position

SuperSubBetting has zero tolerance for modern slavery and human trafficking in any form. The business will not knowingly engage with any supplier, contractor or service provider who is involved in such practices.

5. Supply chain risk assessment

SuperSubBetting's supply chain is very limited and low risk:

• Digital services only: The business engages cloud hosting, analytics, development tools and other established commercial service providers.
• No physical goods: No manufacturing, logistics or physical product supply chain exists.
• No employees: There are no employed workers. Any freelancers engaged are instructed to confirm they work voluntarily, are legally entitled to work in the UK, and are paid at or above the National Minimum Wage.
• Operator counterparties: Where an operator is licensed by the UK Gambling Commission or another authority, that regulatory context forms part of the counterparty review.

Risk of modern slavery or human trafficking in this business's supply chain is assessed as very low.

6. Practical controls

• Any freelance or contractor engagement includes confirmation that the individual works freely and is paid at or above the applicable minimum wage.
• Service providers are checked at onboarding for obvious red flags (e.g. structurally opaque payment arrangements, pressure to use informal workers).
• The business uses only established platforms and operators with published policies of their own.

7. Reporting and escalation

If the sole trader becomes aware of, or suspects, any modern slavery or human trafficking in connection with the business or its supply chain:

1. Cease engagement with the relevant party immediately.
2. Report concerns to the Modern Slavery Helpline: 0800 0121 700 or at modernslaveryhelpline.org.
3. Report to the National Crime Agency or relevant police force if there is evidence of criminal activity.
4. Notify any affected commercial counterparty within five working days.

8. Record-keeping

This policy is retained and dated. Any concern, investigation or report is documented and held for a minimum of six years.