Modern Slavery Statement

SodaFlexx International BV fully supports the aims of the Modern Slavery Act 2015 (the “Act”) and is committed to a zero-tolerance approach to forced labour, slavery, and human trafficking in any form in any part of our business, or supply chain. 


Our policies on slavery and human trafficking 

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery policy reflects our commitment to act ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking 

SodaFlexx frequently reviews its suppliers for adherence to our values and alignment with our policies. We strive to keep our supply chain as local and simple as possible, prioritising working directly with trusted and regular suppliers.

The UK services industry is not considered a high-risk sector for modern slavery. However, we are not complacent and recognise the possibility that modern slavery issues may exist somewhere in our supply chain. We expect transparency from our suppliers and will work with our business partners to support them in driving positive change. In the event that we become aware of any modern slavery issues within any of our supply chains, this would be escalated to senior management through our enterprise risk management framework and appropriate action taken. Depending on the circumstances, this may range from encouraging a supplier to make a positive change to terminating the relationship with a supplier.

Business structure and organisation

We are headquartered in London, United Kingdom and have a strong eco-system with our affiliates, suppliers, clients, partners, and sponsors all jointly aligned to achieve our goals and initiatives.

We work directly with a diverse range of companies as part of our offerings, and with 25+ suppliers who provide us with various goods and services. The majority of our spending is with suppliers of fully managed outsourced services: IT, professional services, and goods and services related to our core offerings.

We have a modern slavery working group with cross-business representatives from senior management, finance, procurement, operations, human resources, and risk & compliance, who ensure we continuously review and improve our approach. Barry Bednar, Chief Executive Officer, is the executive sponsor.

Operational approach

Given our business model, a key way we can drive change is through how we procure, partner, source, engage, and supply and we incorporate environmental, social and governance (ESG) considerations into our day to day operations across all facets of the business. We take our responsibilities seriously and seek to encourage the adoption of best-practice ESG standards, with a view to protecting and enhancing the value of our clients’ and our investments.

We assess modern slavery risk as part of our on-going evaluation of a company’s approach to ensuring respect for human rights. We expect that the companies in which we invest meet internationally recognised human rights standards and industry best practices. We also expect companies to report to shareholders regarding policies, practices and the performance of all the steps taken to address human rights issues. Where we believe a company is exposed to modern slavery risk and not taking action to mitigate this risk, we will incorporate this into our assessment and engage with the company to drive positive change.

Code of conduct

Our code of conduct describes the principles and standards that we hold ourselves to and we ask all our employees to consider these in every decision and action that they take. Within the code, we specifically highlight our commitment to tackling modern slavery.

Supplier code of conduct

Our supplier code of conduct sets out the standards we expect from our suppliers. It specifically highlights the UK Modern Slavery Act 2015 as well as our wider interest and focus on ensuring that human rights and labour standards are respected. We ask our suppliers to inform us if they have any issues or concerns on the policies (third party management, outsourcing, corporate transactions, and people). These policies form part of our enterprise risk management framework and support our commitment to tackling modern slavery through our interactions with our suppliers, our people, and new business partners. Each policy owner is required to complete and sign-off a quarterly certification confirming the business area’s adherence to the policy, and where necessary, develop action plans to resolve any issues of non-compliance with policy standards. Regular updates on policy compliance are reported to our Board-level Risk and Capital Committee.


To raise awareness amongst our employees of both modern slavery and the speak up arrangements available to them, we have started to incorporate these into our mandatory code of conduct annual training.

Raising awareness

Throughout 2022 we sought to use our influence to raise awareness of the scale of modern slavery and encourage and mobilise others to be part of a momentum for change. We participated in a modern slavery webinar with the Institute for Corporate Responsibility and Sustainability, and marked both International Day for the Abolition of Slavery and Human Rights Day with awareness raising activity for our employees.

Due diligence and risk assessment of suppliers

Heightened modern slavery and human trafficking risk exists in relation to certain territories, and in relation to the production of certain goods and supplies. We are working with a leading third party to undertake a risk assessment of our suppliers which we have identified as presenting the greatest risk of modern slavery. This will enable us to prioritise our activity accordingly including effectively managing any existing suppliers identified as presenting a risk, making responsible sourcing decisions, and further developing and enhancing our compliance with our regulatory obligations. This activity will be reviewed and updated during 2022 and beyond.


Our progress against our key performance indicators is as follows:

We started raising awareness amongst our employees of modern slavery issues and how to respond. 100% of our people have started on our code of conduct training.

We complete modern slavery risk assessments of our suppliers. In 2021 we started a pilot to further risk assess a targeted subset of our suppliers using a third party service. When we have a baseline year of data from this we will put in place indicators relating to the risk assessment and management of suppliers.

Modern slavery considerations are integrated into our “Operational Approach” process. See section ‘Operational Approach’ which details our integration.

This Statement was approved by SodaFlexx International BV and is signed by:


Chief Technical Officer & Founder

Sander Castel