MoneeMint Limited opposes all forms of slavery which consists of but is not limited to human trafficking, drug trafficking, sex trafficking, and unpaid labour. We make this statement to set out the steps we have taken to adhere to the requirements of the Modern Slavery Act 2015 and to reflect a drive to eradicate modern slavery in commercial organisations within our supply chain.
Policies on slavery, forced or compulsory labour, and human trafficking
MoneeMint Limited will conduct all business with integrity and due care, we have a zero-tolerance approach to modern slavery risks. Therefore, MoneeMint Limited is fully committed to working and operating by the International Bill of Human Rights (comprising the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights). We also consider the UN Framework and Guiding Principles and other internationally accepted human rights standards.
Global Modern Slavery Policy
MoneeMint Limited’s Global Modern Slavery Policy 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 across our supply chains.
Global Whistleblowing Policy
MoneeMint Limited’s Global Whistleblowing Policy encourages employees to play a key role in preventing and detecting wrongdoings within the company. Employees are encouraged to raise their concerns about any suspected or known criminal conduct or any other type of misconduct taking place through the company, its customers or third parties. Employees can raise disclosures anonymously and confidentially in line with MoneeMint Limited’s Whistleblowing Policy.
Global Employment Policy
We treat all employees with dignity and respect to foster an environment that is free from discrimination, harassment, and any form of bonded or forced labour. Our commitment to respecting human rights in the workplace is embedded within our values and employment policies and practices.
All employees are made aware of their employment rights through a variety of channels including written employment contracts, employee handbooks, and internal communications. Employees receive in person 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.
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
- Building services and contracts
- Cleaning services
- Security services
- Manufacturers of MoneeMint Limited’s merchandise, marketing materials and products
- Professional services including but not limited to legal firm, accountants and any other supplier that is not categorised above.
Third-Party Due Diligence
MoneeMint Limited deals with a broad range of Third Parties, and it is our intention to only contract with third parties who can satisfy our standards with regards to employment and welfare conditions. To help identify and monitor the risk of slavery and human trafficking in our supply chain we conduct due diligence on existing and new third parties considering three risk factors:
- The country the third-party operates in (and has supply chains in)
- The sector the third-party operates in; and
- The products produced, manufactured, or supplied by the third-party
MoneeMint Limited adopts a risk-based approach to address modern slavery risks. For high-risk third parties, MoneeMint Limited will request the completion of modern slavery due diligence questionnaires. The basis for the risk-based approach applied to third parties derives from two sources:
- The Global Slavery Index, and
- The Global Estimates of Modern Slavery
The Global Slavery Index
The Global Slavery Index is a leading global indicator of modern slavery worldwide. This index addresses three factors in particular:
- Size of the problem: the prevalence of modern slavery in each country
- Government response: governmental response to the problem of modern slavery
- Vulnerability: factors that explain/predict the presence of modern slavery
The Global Estimates of Modern Slavery
The Global Estimates of Modern Slavery is another global indicator of modern slavery worldwide, which was developed by the International Labour Organisation (ILO) and the International Organisation for Migration (IOM). This indicator provides the estimates for modern slavery globally. These estimates were used as a starting point for the Global Slavery Index.
We include our standard modern slavery clauses in our supplier contracts and purchase orders’ standard terms and conditions. We go through an escalation and sign off process with the business to consider the risks of any supply contract. These clauses seek to manage modern slavery risks and ensure that we receive appropriate information on suppliers’ supply chains and organisations, including copies of their modern slavery statements if they are required to report under the UK Modern Slavery Act.
Our suppliers have a contractual obligation to ensure compliance with all applicable laws that apply to their supply of goods and services to us, regardless of the jurisdiction in which they operate. This includes the UK Modern Slavery Act and any local legislation that is aimed at combating modern slavery.
MoneeMint Limited has established modern slavery in person learning through our Compliance Function that focuses on how we mitigate the risk of modern slavery and human trafficking in our supply chain, our third parties, and customer base and direct operations. This training is mandatory for all employees at MoneeMint Limited (including, Board members and temporary workers).
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. MoneeMint Limited’s 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 are encouraging people to report any signs of modern slavery and human trafficking to Unseen UK. All reports will be received by the Modern Slavery officer (“MLRO”), which works closely with law enforcement agencies, non-governmental organisations. The training aims to develop employee awareness of what constitutes criminal activity, the indications of this and how to report concerns of suspicious activity.
This statement has been approved by Hassan Waqar- Chief Executive Officer on 22nd April 2022