Policy

Modern Slavery Statement

1. Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that WagePerks Ltd ("the Company") has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within our business or supply chain.

WagePerks Ltd is committed to acting ethically and with integrity in all business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere within our own business or in any of our supply chains.

2. About WagePerks Ltd

WagePerks Ltd is a company registered in Scotland that operates an employee management portal providing employer clients with a range of services including employee benefits and discounts, 24/7 GP access, an Employee Assistance Programme, HR management tools, and shift and rota management.

Our platform serves employers across multiple sectors in the United Kingdom, including hospitality, retail, care, construction, and logistics. Through our platform, we process personal data relating to employees and provide them with access to benefits and support services.

3. Our Supply Chain

As a technology company delivering digital services, our supply chain includes:

  • Technology and infrastructure providers -- cloud hosting, software-as-a-service providers, and data centre operators that support the WagePerks platform.
  • Benefits and discount partners -- retailers, service providers, and aggregators through which employee discounts and benefits are delivered.
  • Healthcare service providers -- providers of the 24/7 GP access service and Employee Assistance Programme delivered through the platform.
  • Professional service providers -- legal, accounting, audit, and consultancy firms engaged by the Company.
  • Recruitment agencies -- where used to source temporary or permanent staff.
  • Office services and facilities providers -- including cleaning, maintenance, and equipment suppliers.

4. Risk Assessment

We have assessed the risk of modern slavery occurring within our business and supply chain. Given that WagePerks Ltd is primarily a digital services company operating within the United Kingdom, the direct risk within our own operations is assessed as low. However, we recognise that risks may exist within our wider supply chain, particularly in relation to:

  • Lower-skilled service roles within our facilities management supply chain, where workers may be more vulnerable to exploitation.
  • Overseas elements of our technology supply chain, where hardware components or data centre services may be sourced from jurisdictions with higher prevalence of modern slavery.
  • Recruitment agencies, where there is a risk that unethical labour sourcing practices could occur.
  • The sectors served by our clients, including hospitality, care, and construction, which are identified by the UK Government as higher-risk sectors for labour exploitation.

5. Our Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

  • Code of Professional and Ethical Conduct -- sets out the standards of behaviour expected of all Personnel and establishes our commitment to ethical business practices.
  • Whistleblowing Policy -- encourages all Personnel, suppliers, and partners to report concerns about any aspect of the Company's business, including suspected modern slavery, without fear of retaliation.
  • Recruitment and Selection Policy -- includes processes to verify the identity, right to work, and employment status of all individuals engaged by the Company, including agency workers.
  • Equality, Diversity and Inclusion Policy -- ensures fair treatment and respect for all individuals.
  • Supplier Code of Conduct -- sets out the minimum standards expected of all suppliers, including compliance with the Modern Slavery Act 2015 and relevant employment legislation.

6. Due Diligence Processes

The following due diligence processes are in place to identify and mitigate the risk of modern slavery:

6.1 Supplier Due Diligence

  • All new suppliers are subject to a due diligence process that includes an assessment of modern slavery risk.
  • Suppliers assessed as higher risk are required to provide evidence of their own modern slavery policies and procedures.
  • Contracts with suppliers include clauses requiring compliance with the Modern Slavery Act 2015 and granting the Company the right to audit and terminate in cases of non-compliance.
  • Existing supplier relationships are reviewed periodically to ensure continued compliance.

6.2 Employment Practices

  • We verify the identity and right to work in the UK of all employees before employment commences, in compliance with the Immigration, Asylum and Nationality Act 2006.
  • We ensure that all employees receive at least the National Minimum Wage or National Living Wage as applicable, paid directly to them.
  • We do not require employees to pay any fees or deposits as a condition of employment.
  • We do not retain employees' identity documents.
  • We ensure that all working hours are in compliance with the Working Time Regulations 1998.

6.3 Recruitment Agencies

  • We only engage recruitment agencies that can demonstrate compliance with the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, and the Modern Slavery Act 2015.
  • We require agencies to confirm that workers supplied to us have the legal right to work in the UK and are being paid at least the applicable minimum wage.

7. Training and Awareness

We provide training and awareness on modern slavery to all Personnel:

  • All employees receive awareness training on modern slavery as part of their induction, covering the definition of modern slavery, how to identify potential signs, and how to report concerns.
  • Employees in procurement, HR, and management roles receive enhanced training tailored to their responsibilities.
  • Training is refreshed annually to ensure that awareness remains current.

8. Indicators of Modern Slavery

We train our Personnel to be aware of the signs that may indicate modern slavery, including but not limited to:

  • Individuals appearing to be under the control of another person or reluctant to interact with others.
  • Individuals who appear malnourished, unkempt, or anxious.
  • Individuals living and working at the same address.
  • Individuals who have had their identity documents confiscated.
  • Individuals who appear to be working excessively long hours, below the minimum wage, or in poor conditions.
  • Individuals who show signs of physical abuse, restraint, or confinement.

9. Reporting Concerns

Any person who has concerns about modern slavery in relation to WagePerks Ltd or its supply chain is encouraged to report those concerns through:

  • Their line manager (for employees).
  • The Company's whistleblowing procedure.
  • The Company Secretary.

Externally, concerns may also be reported to the Modern Slavery Helpline on 08000 121 700 or the National Crime Agency.

All concerns will be taken seriously and investigated promptly. No individual will be subjected to any detriment for raising a genuine concern about modern slavery.

10. Performance Indicators

We use the following key performance indicators to measure the effectiveness of our approach:

  • The percentage of new suppliers that have completed modern slavery due diligence.
  • The number of modern slavery concerns reported and the outcomes of investigations.
  • The percentage of Personnel who have completed modern slavery awareness training.
  • The results of any supplier audits conducted.

11. Our Commitment

WagePerks Ltd is committed to continually improving its practices to combat modern slavery and human trafficking. We will:

  • Continue to review and strengthen our due diligence processes.
  • Engage with our supply chain partners to promote awareness and compliance.
  • Monitor developments in legislation, guidance, and best practice.
  • Report transparently on our efforts and progress in each annual statement.

12. Approval

This statement has been approved by the Board of Directors of WagePerks Ltd and will be reviewed and updated annually.

Policy Owner: Board of Directors, WagePerks Ltd

Last Reviewed: April 2026

Registered in Scotland