Modern Slavery Act
Modern slavery and human trafficking statement

1. Introduction

Modern slavery and human trafficking are serious and often hidden crimes which can be devastating for the victims.
Modern slavery includes labour exploitation, sexual exploitation, domestic servitude, and criminal exploitation. Human trafficking is defined as arranging or facilitating the travel of another person with a view to exploitation and includes travel within a country, not just across international borders.This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Moneliq Limited to prevent modern slavery and human trafficking in its business and supply chains.
As an ethically driven company, we will conduct all business with integrity, having a zero-tolerance approach to modern slavery and human trafficking risks.We are committed to ensuring transparency within our business and supply chain; and ensuring our approach to tackling modern slavery and human trafficking is consistent with our disclosure obligations under the Modern Slavery Act 2015. We endorse the implementation and promotion of ethical business practices to protect our staff from abuse and exploitation and expect the same high standards from all our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.

2. Our approach to slavery and human trafficking

Our approach reflects our commitment to acting ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure that slavery (including human trafficking, drug trafficking, sex trafficking, and national minimum wage violations) is not taking place at any point in our supply chains.
Impact on Our Supply Chains
Our supply chains are made up of the following:
  • IT services and communications including customer support activities
  • financial institutions and payment processors
  • security services; and
  • manufacturers of Moneliq merchandise and products.

3. Employment Policies

The Company treats all employees with dignity and respect to foster an environment that is free from discrimination, harassment, and any form of bonded or forced labour.
Moneliq has procedures in place pertaining to our employment practices:
  • Recruitment processes in line with local labour laws, including ‘right to work’ document checks, contracts of employment, and checks to ensure all employees are above the minimum working age.
  • Moneliq employees are made aware of their employment terms and conditions through a variety of channels including but not limited to written employment contracts and internal communications.
  • Market - related pay and reward, which is reviewed regularly and linked to financial services benchmarks.
  • Employees receive training on core human rights-related issues, including but not limited to diversity and inclusion, money laundering, third-party risk management, and bribery and corruption.

4. Whistleblowing Policy

The Company’s Whistleblowing policy is communicated to employees during their site induction. The intention of the policy is to outline the process for employees to report instances of corruption, malpractice, criminal behaviour, and failure to deliver proper standards of service, where confidentiality is required. This policy is integral in preventing occurrences of modern slavery and human trafficking by providing an avenue whereby any suspected instance can be reported without fear of repercussions.

5. Due Diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk, the Company has in place processes to identify and assess potential risk areas in Moneliq and our supply chains and assess the effectiveness of such actions.
These include:
  • carrying out due diligence on third parties, including an assessment as to whether third parties or they supplier chain has a heightened risk of modern slavery
  • monitoring potential risk areas in our supply chains by reviewing our relationships with suppliers on a periodic basis proportionate to their level of overall risk to the Company
  • setting the bar high for the work we do and the way our employees behave. We show consideration and empathy, live by our values, and in this way we create an open, supportive culture where people can flourish, do their best work, and feel supported to escalate concerns they may have about our business or suppliers. We're also clear on how we treat unacceptable behaviour, so we can continue to protect the culture we have built
To ensure all those in Moneliq's supply chain and contractors comply with our values, we have in place a supply chain compliance programme. This includes carrying out the due diligence process referred to above as to the potential level of risk of slavery and human trafficking for third parties.

6. Training

To ensure there is understanding of the risks of modern slavery and human trafficking in our supply chains and our business, Moneliq has training, ethics, disciplinary, and whistleblowing policies and procedures in place.
These policies and procedures allow and encourage Moneliq to raise any concerns, and for the Company to take appropriate corrective action if necessary, including with respect to slavery or human trafficking.Modern slavery and human trafficking (including drug trafficking and sex trafficking) are crimes and those responsible will seek to launder the proceeds in the financial system to legitimise them. The Company’s responsible department within the Financial Crime Compliance function leverages intelligence, investigations, analytics, and technology to deter financial crime. This enables us to identify existing or emerging risk issues and financial crime quickly and effectively, to ensure that we are focused on how criminals seek to exploit our services in their pursuit of financial gain.
As part of our training, we encourage people to report any signs of modern slavery and human trafficking to local authorities. The training aims to develop employee awareness of what constitutes criminal activity, the indications of this and how to report concerns of suspicious activity.

7. Planning

  • Continue to ensure that Modern Slavery and Human trafficking learning training is completed by key employees
  • Continue to monitor and report on the use of employee grievance mechanisms for any association with modern slavery
  • Continue to respond to guidance and changes in legislation on Modern Slavery and Human Trafficking
  • Continue to monitor and evaluate effectiveness of controls designed to mitigate Modern Slavery and Human Trafficking risks