Modern Slavery Statement

Modern Slavery Act Transparency Statement


Since the 29th October 2015, the Modern Slavery Act 2015 came into effect and requires commercial organisations to publish an annual statement if all the criteria below apply

  • it is a ‘body corporate’ or a partnership, wherever incorporated or formed
  • it carrieson a business, or part of a business, in the UK
  • it supplies goods or services
  • it has an annual turnover of £36 million or more

As Boku is meeting all those requirements, and as part of our commitment to conducting our business ethically and with integrity, Boku is issuing this statement to provide transparent information regarding the steps taken to prevent slavery and human trafficking from occurring within our business and supply chain.

Boku has zero tolerance for any kind of modern slavery including but not limited to slavery, forced labour or servitude, human trafficking, or any unethical practices. We recognise our responsibility to:

  • Continuously review the steps we take to prevent modern slavery and human trafficking.
  • Conduct due diligence on all our commercial partners to ensure they use fair and ethical labour practices.
  • Provide clear instructions to all our staff and partners regarding their obligation to act with integrity.

Our business and supply chain

Boku offers payment services to merchants through direct carrier billing and other various payment methods, allowing our partners to accept payments from users based anywhere in the world using any currency. Boku does not operate any factory, produce any goods nor is involved with raw materials or commodities. However, we source products and services from various suppliers located anywhere in the world, including the E.U.
Due to the nature of our business Boku’s main suppliers are mostly involved in IT and Marketing services.

Our policies

Boku’s commitment to meet the highest ethical standards in all its business activity is embedded in our culture, hence it is mandatory upon onboarding for each employee to read and agree to a set of policies including the employee ethics and conduct standards (“The Code of Conduct”). The Code stresses Boku’s commitment to ensure that all its employees always act in ethical manner, with integrity and are treating everyone with respect and dignity. We value our employees’ continuing success and we believe that our success as a payment services provider is intimately linked to our ability to uphold the highest professional and ethical standards throughout the business and treating all individuals with due respect.

Our due diligence processes

As part of our onboarding process, we conduct due diligence on all our prospective partners or suppliers, applying a risk-based approach to ensure that all our partners are meeting our highest standard.


We believe that training and educating our staff is a key element to prevent the risk of modern slavery and human trafficking in our business and supply chains, therefore our employees are encouraged and trained to identify and report any potential violations.

Board Approval

Boku issues this statement in compliance with the section 54 (1) Modern Slavery Act 2015 (the “Act”), which will constitute our statement of transparency for the financial year ending 31 December 2023. Approved at a meeting of the Board of Directors on March 13, 2024. Signed on behalf of the Board by Dr. Richard Hargreaves on March 13, 2024.

Dr. Richard Hargreaves
March 13, 2024

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