Modern Slavery Act Transparency Statement
Boku, Inc.
Modern Slavery Act Transparency Statement
Introduction
Since the 29th October 2015, the Modern Slavery Act 2015 (the “Act”) came into effect and requires commercial organisations to publish an annual statement of the following criteria below:
- it is a ‘body corporate’ or a partnership, wherever incorporated or formed
- it is 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
Boku currently meets all those requirements, and as part of its commitment to conduct business ethically and with integrity, is issuing this statement pursuant to section 54(1) of the Act to provide transparent information regarding the steps taken to prevent slavery and human trafficking from occurring within its business and supply chains.
For the purposes of this statement, “modern slavery” refers to slavery, servitude, forced or compulsory labour and human trafficking, all of which involve the deprivation of a person’s liberty for personal or commercial gain.
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, whether within its own operations or its supply chains. Boku recognises its responsibility to:
- Continuously review the steps it takes 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
Boku’s business and supply chains
Boku offers payment services to merchants through direct carrier billing and other various payment methods, allowing its 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, it sources products and services from various suppliers located anywhere in the world, including the EU.
Due to the nature of its business Boku’s main suppliers are mostly engaged in technology, IT infrastructure, cloud services, professional services and marketing and are located across a number of jurisdictions.
Boku has assessed the potential risk of modern slavery within its business and supply chains and considers this risk to be relatively low, given its position as a technology-enabled payments business and the absence of manufacturing or labour-intensive activities. Notwithstanding this assessment, Boku recognises that risks may arise in relation to third-party suppliers and remains vigilant in mitigating such risks.
Boku’s policies
Boku’s commitment to meeting the highest ethical standards in its business activities is embedded in its 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 ensuring that all employees act in an ethical manner, with integrity and treat others with respect and dignity. Boku values its employees’ continuing success and Boku believes that its success as a payment services provider is intimately linked to its ability to uphold the highest professional and ethical standards throughout the business and treating all individuals with due respect.
Boku also expects its suppliers and business partners to adhere to equivalent standards of ethical conduct and to comply with applicable labour and employment laws.
Boku’s due diligence processes
As part of its onboarding process, Boku conducts risk-based due diligence on prospective partners or suppliers to assess, among other things, their approach to ethical business practices and compliance with applicable laws.
Where concerns relating to modern slavery or human trafficking are identified, Boku expects appropriate remedial action to be taken and may take steps up to and including termination of the relevant commercial relationship.
Training
Boku believes that training and educating its staff is a key element to prevent the risk of modern slavery and human trafficking in its business and supply chains, therefore our employees are encouraged to identify potential indicators of modern slavery and human trafficking and to report any concerns through appropriate internal channels.
Effectiveness and Review
Boku keeps the effectiveness of the measures described in this statement under review, including through periodic assessment of its policies, supplier engagement and internal processes. This statement will be reviewed and updated on an annual basis.
Board Approval
Boku issues this statement in compliance with the section 54 (1) of the Act, which will constitute its statement of transparency for the financial year ending 31 December 2025.
Approved at a meeting of the Board of Directors on 14 January 2026.
Signed on behalf of the Board by Richard Pennycook on 14 January 2026.
Richard Pennycook
Chair