Wagestream Anti-Slavery and Human Trafficking Statement

October 2019

Background

Wagestream was founded with the desire to be a strong cause for social good, in making it possible for workers to gain fast access to accrued earnings and this is embedded in the ethos of the company, including a social charter designed in conjunction with our charity investors in the Articles of Association which state:

The Company’s primary objective is to advance, for the public benefit, technology solutions to help workers, including those that are on low income, escape the cycle of debt by being able to access their earned wages at any time (the “Social Purpose”), and as a secondary object, to secure a reasonable return to its Shareholders while having regard to the need to promote the Social Purpose.

At Wagestream we are therefore strongly committed to ensuring that our organisation is free from slavery and human trafficking and that all Wagestream colleagues as well as the people who work on our behalf are protected. We envision a world where all people and communities thrive because they are living with economic stability and social equality and this is the core principal behind our business and purpose.

As a software company, our business model does not carry with it a high level of slavery risk compared to businesses operating in other sectors such as manufacturing and retail. This statement therefore covers those areas within our business supply chain which we have identified as presenting a potential slavery risk. We will continue to focus on these areas until we are satisfied that we have mitigated all associated risks. 

Structure

Wagestream was set up in 2018 as a force for good, in order to prevent employees entering cycles of debt caused by loans, overdraft fees, high-cost-credit and payday loans and we are proud to work with social impact charitities to help employees manage their money better. 

Wagestream is the market leader for integrated income streaming, allowing employees to access their earned salary before the normal pay cycle. We work with employers and employees to enhance the financial wellbeing of staff. 

Currently all of Wagestream’s operations in terms of revenue generation are concentrated in the United Kingdom and Ireland, with some support services located in the United States. 

Our Employees

Wagestream operates a rigorous recruitment selection process for all hiring decisions which includes obtaining documented proof of the individual’s right to work in the country in which they will be employed. We will always pay colleagues at least the minimum wage rate applicable in the geography in which they work (and are committed to paying the London living wage for employees based in London). Our relationship with our colleagues starts at the hiring stage, and we aim to ensure that everyone is treated fairly and with compassion throughout their time at Wagestream, with all the rights and benefits that colleagues are entitled to by law enhanced by our additional wellbeing offerings.

We employ people from a diverse range of backgrounds who all share, and subscribe to, the ambitions and values of our business. All our employees undertake a learning and development programme which includes training in relation to: · 

• the regulatory environment in which we conduct our business; and 

• the policies, practices and professional standards we adopt. 

Our Employee Code of Conduct provides a clear set of rules for all colleagues and the standards of behaviour expected across all areas of our business including in relation to modern slavery concerns. 

Our Policies, processes and procedures

We are committed to act with integrity in all of our business activities and to comply with all applicable laws and regulations to which we are subject. Our relevant policies include those relating to: · 

• anti-money laundering and counter-terrorist financing; 

• conflicts of interest; 

• anti-bribery and corruption; 

• whistleblowing; 

• the protection of data and data confidentiality 

We have developed standards, processes and procedures including: 

• asking suppliers to adhere to our supplier code of conduct; 

• the monitoring and review of the effectiveness of our internal policies and their implementation; 

• those to support an inclusive, open and tolerant workplace environment; and 

• those relating to the raising of concerns or poor practice by our employees and those with whom we deal. 

Our Supply Chain 

Our supply chain service partners principally involve suppliers of technology, data, office and facilities supplies, and professional advisory firms, amongst others. We undertake due diligence on proposed suppliers to ensure that they are a suitable organisation with which to do business. 

We do not tolerate slavery and/or human trafficking within our supply chains and would seek to terminate our relationship with a supplier where evidence of this occurred. 

Given the nature of our business, we do not consider that we operate in a sector where modern slavery and human trafficking are particularly prevalent or of high risk, however through our due-diligence and assurance frameworks (which continue to evolve as our business grows) we continue to monitor our outsourcing policies and procedures to ensure that our supply chain services partners comply with, and are aligned to, our values and our commitment to ensure that there is no slavery or human trafficking arising in our supply chains or in any part of our business. We ask all our suppliers to adhere to our supplier code of conduct which sets out clearly our expectations and the standards of behaviour we expect from all our suppliers across a range of issues, and specifically fair treatment of their employees, and slavery and human trafficking in their own supply chains.

WAGESTREAM LTD, 2019