Modern slavery statement

Sorteo Ltd is well below the size at which the law requires a statement like this. We are publishing one anyway, because the right time to decide how you buy is before you are big enough to have to.

What our supply chain actually is

Bottle is software. We do not manufacture anything, we hold no stock, we ship no goods, and we own no premises beyond a registered office address. Almost everything we buy is a software service bought online from an established company: computing power to run Bottle on, a payments company, an email service, a domain and website provider, and the services that deliver notifications to phones. Every one of them is named, with what they do and where they are, on our third parties page.

We do not use employment agencies, labour providers, outsourced workforces or subcontracted manual labour of any kind. There is nobody in our supply chain doing physical work on our behalf.

Why we think the risk is low, rather than just saying it is

Forced labour and human trafficking cluster where work is physical, low paid, seasonal, subcontracted several layers deep, or carried out by people whose immigration status makes them easy to exploit. Manufacturing, agriculture, construction, cleaning, care and logistics are where it is most often found. None of those describes what we buy.

Our suppliers are large technology companies in the United Kingdom, the European Union and the United States. Several of them are big enough to be caught by section 54 themselves and publish their own statements, which is a stronger check on them than anything a company of our size could carry out.

That said, low risk is not no risk. Data centres are built and maintained by people, and hardware is manufactured somewhere. Those are real supply chains sitting behind the services we buy, and we are two or three steps removed from them with no practical visibility. We would rather write that down than pretend our distance from it is the same as an assurance.

What we actually do

• We buy from established companies with a public reputation to lose, rather than from the cheapest supplier we can find.
• We expect our suppliers to meet at least the standards set out here, and we would treat a credible allegation against one of them as a reason to stop using them.
• We keep the list of who we buy from short, public and current, so it can be checked by anyone rather than taken on trust.

We do not carry out supplier audits, we do not run a training programme, and we do not maintain a formal risk assessment. A company of one person claiming to do those things would not be telling you the truth, and a policy that describes a process nobody follows is worse than no policy at all.

If we found a problem

If we found or were told about forced labour, trafficking or exploitation connected to anyone we buy from, we would stop buying from them, say publicly that we had, and report it to the Modern Slavery Helpline on 08000 121 700 or to the police. We would not sign a confidentiality agreement about it. If the problem were somewhere we could genuinely influence rather than simply walk away from, we would say so and explain what we were doing instead.

What changes as we grow

When we take people on, whether as staff or as contractors, we check their right to work properly, pay at least the legal minimum, never ask anyone to work an unpaid trial, and never hold anyone's identity documents. If we ever buy physical goods, such as handsets or vehicle equipment for customers, that is a genuinely different supply chain and we will look at it properly before we start rather than afterwards.

If our turnover reaches the point where section 54 applies, this becomes a legal duty with a set form, board approval and a director's signature, and we will meet it.

Asking us about this

If you need something more detailed for a procurement process or your own records, email hello@getbottle.app and tell us what it needs to cover. We will either answer properly or tell you honestly that we cannot.