Modern Slavery and Human Trafficking Statement

Supplier name: Billmonitor (registered as Optimor Limited)

Publication date: 21 April 2026

Introduction

This Modern Slavery Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the “Act”). Although Billmonitor is not classified as a relevant commercial organisation under Section 54 of the Act, we have voluntarily chosen to publish this Statement in line with our commitment to responsible and ethical business practices.

For the purposes of this Statement and associated policy, the term “Modern Slavery” includes slavery, servitude, human trafficking, forced or compulsory labour, and child labour.

We are committed to conducting our business ethically, with integrity and transparency, and to implementing effective systems and controls to prevent modern slavery within our operations and supply chains.

Organisation Structure, Business and Supply Chains

Billmonitor is a private limited company providing mobile tariff advisory services to both private and public sector clients across the UK. Our core activities include:

One-off Bill Audit and Contract Reviews – Delivered as part of contract renewals or as standalone services to identify historical billing issues, assess current usage, and highlight potential cost savings during the contract term.
Ongoing Bill Monitoring – Includes our monthly Billmonitor Usage and Spend Analysis, designed to identify irregular usage patterns and prevent cost escalation following contract renewal. Clients receive a monthly report highlighting exceptional cost items and, where appropriate, recommendations for improvement.
Remote Account Management and Mobile Technology Support – Provides comprehensive day-to-day management of clients’ mobile estates, including SIM provisioning, device off-boarding, remote handset support, and liaison with network providers. This service is typically offered as an extension to ongoing Bill Monitoring.
Equipment Audits – Reviews the suitability of mobile devices against user requirements and ensures compliance with clients’ internal cybersecurity standards.

Our supply chains primarily consist of:

Professional service providers, including cloud and software solutions, HR services, and accounting providers; and
Suppliers of mobile handsets, primarily well-established retail providers and suppliers of refurbished devices.

We operate nationally from our London office. While the majority of our work is UK-based, we also support clients’ international operations, liaising with network providers across Europe and the United States where required.

Policies in Relation to Slavery and Human Trafficking

We operate a zero-tolerance approach to modern slavery. Our internal governance framework includes:

Code of Conduct – All employees and representatives are required to uphold the highest standards of integrity and ethical behaviour. Our Employee Handbook incorporates anti-corruption measures and promotes fairness, equality, and responsible conduct.
Whistleblowing Policy – Embedded within the Employee Handbook, this policy ensures that employees can raise concerns confidentially and that such concerns are addressed appropriately.
Recruitment Policy – Supports fair, lawful, and transparent hiring practices, promotes workforce diversity, and includes opportunities such as apprenticeships and funded professional development.

All policies are subject to periodic review and are communicated to relevant stakeholders.

Due Diligence Processes

To identify and mitigate risks, we apply proportionate due diligence measures, including:

Engaging primarily with reputable suppliers known for strong compliance standards; and
Conducting periodic supplier reviews where appropriate.

Where risks are identified, we work collaboratively with suppliers to ensure that appropriate corrective actions are implemented.

Risk Assessment and Management

We recognise that risks of modern slavery may arise in certain areas of our operations and supply chains, particularly in relation to:

Suppliers operating in higher-risk jurisdictions; and
The use of temporary or lower-skilled labour.

To manage these risks, we:

Monitor and review supplier performance where relevant;
Prefer suppliers with lower exposure to high-risk jurisdictions where feasible; and
Review publicly available information on key suppliers, maintaining awareness of supply chain risks reported in the media and industry sources.

No instances of modern slavery were identified during the reporting period. Any concerns identified would be escalated to senior management, with appropriate remedial action taken, including potential termination of supplier relationships where necessary.

Effectiveness and Key Performance Indicators (KPIs)

We assess the effectiveness of our approach through the following indicators:
- Number of reported concerns or incidents; and
- Completion rates for staff training on modern slavery.
We are committed to continuous improvement and aim to strengthen these metrics year-on-year.

Training and Capacity Building

Following the appointment of Quest Cover as our HR advisors and the introduction of a dedicated HR representative, we are enhancing our training and awareness initiatives. These include:

Training on ethical standards, risk identification, and reporting mechanisms; and
Guidance materials to support the recognition of modern slavery indicators within our operations and supply chains.

Training programmes are reviewed periodically to ensure they remain effective and aligned with evolving risks.

Modern Slavery and Human Trafficking Statement