Anti-Slavery & Anti-Trafficking Policy

Anti-slavery and Anti-trafficking Statement and Policy

Anti-slavery and anti-trafficking statement and policy

We, A&B General (UK) Limited (A&B Money, ABPLUS, we or us), are opposed to all forms of slavery, including (without limitation) unpaid labour, human trafficking, sex trafficking and drug trafficking. We uphold ethical standards and act with integrity in all our business relationships and we require the same high standards from our contractors, suppliers and other business partners. We have issued this statement to demonstrate how we comply with the requirements of the UK Modern Slavery Act 2015 (the Act)

Anti-slavery and anti-trafficking statement

(pursuant to Section 54(1) of the Modern Slavery Act 2015)

Legal status and activities

A&B General (UK) Limited has registered in England number no. 6928080. Registered Office: m228, Trident Business Centre,89 Bickersteth Road, London SW17 9SH. Correspondent address 163 Bellville House, 4 John Donne Way, London SE10 9FW A&B General (UK) Ltd is registered with the Financial Conduct Authority under the payment Services Regulations 2009 (no. 716949) for the provision of payment. Data Protection and Freedom of Information advice (ICO): DPA Register no ZA077710.

Policy

A&B General (UK) Limited (A&B Money) has implemented an Anti-slavery and anti-trafficking policy (published below) reflecting its commitment to combatting slavery and human trafficking and to acting with integrity in all its dealings, relationships, and supply chains. The policy outlines how we various procurement and HR practices, policies and procedures ensure compliance with its policy commitment.

Our Comittment to the principles of the modern slavery Act 2015

A&B Money is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.

As an equal opportunity’s employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves.

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Health and Safety

Purpose of policy

AB Plus take health and safety issues seriously to protecting the health and safety of its staff and affected by its business activities and attending its premises. This policy is intended to help Employer clarify who is responsible for health and safety matters and what their responsibilities are. However, this policy does not form part of your contract of employment or any other contract for work or services. This policy may be amended at any time by the Employer at its absolute discretion.

What employers must do for you

1. Decide what could harm you in your job and the precautions to stop it. This is part of risk assessment.
2. In a way you can understand, explain how risks will be controlled and tell you who is responsible for this.
3. Consult and work with you and your health and safety representatives in protecting everyone from harm in the workplace.
4. Free of charge, give you the health and safety training you need to do your job.
5. Free of charge, provide you with any equipment and protective clothing you need, and ensure it is properly looked after
6. Provide toilets, washing facilities and drinking water
7. Provide adequate first-aid facilities
8. Report major injuries and fatalities at work to our incident contract centre on 0345 300 9923. Report other injuries, diseases and dangerous incidents online at www.hse.gov.uk
9. Have insurance that covers you in case you get hurt at work or ill through work. Display a hard copy or electronic copy of the current insurance certificate where you can easily read it.
10. Work with any other employers or contractors sharing the workplace or providing employees (such as agency workers), so that everyone’s health and safety is protected.

Responsibilities of all staff

General staff responsibilities

1. Follow the training you have received when using any work items your employer has given you.
2. Take reasonable care of your own health and safety and other people’s health and safety.
3. Co-operate with your employer on health and safety.
4. Report all health and safety concern (your employer, supervisor, or health and safety representative) if you think the work or inadequate precautions are putting anyone’s health and safety at serious risk.
5. Keep the workplace tidy and hazard-free.
6. Co-operate in the Employer’s investigation of any incident or accident which either has led to injury or which, in the Employer’s opinion, could have led to injury.

Staff responsibilities relating to equipment

1. Use equipment as directed, following any instructions given by representatives of management or contained in any written operating manual or instructions for use, and adhering to any relevant training.
2. Report any fault with, damage to, or concern about any equipment (including health and safety equipment) or its use to the Health and Safety office, who is responsible for maintenance and safety of equipment.
3. Ensure that health and safety equipment is not interfered with.
4. Not attempt to repair equipment unless suitable trained and authorised.

Our Supply Chain

Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains.

Our supply chains are limited, and we procure goods and services from a restricted range of UK and overseas suppliers, mainly through UK government frameworks.

The UK SBS (our shared services provider) has also published its statement on slavery and human trafficking. This includes mechanisms for guarding against modern slavery in its clients’ supply chains.

Our supply chains include:

• Financial institutions, liquidity providers and payment processors.
• Building and facilities management services.
• IT services.

Our policies in relation to the Modern Slavery Act 2015

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies. For example:

• Our business Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.
• Our Whistleblowing Policy promotes participation from employees in preventing and uncovering wrongdoing. Our employees are urged to express concerns regarding potential criminal activities or any form of misconduct occurring within IFX, involving its employees, customers, or third parties.
• We uphold a commitment to treating all employees with dignity and respect, fostering a discrimination-free and harassment-free workplace that rejects any form of bonded or forced labour. Furthermore:

The information has related to below policies

• Recruitment and selection policy
• Job Agreement
• Health and Safety Policy for AB PLUS
• Compliant Policy
• Whistleblowing Policy

Embedding the principles

We will continue to embed the principles through:

• providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking.
• ensuring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK
• ensuring that consideration of the modern slavery risks and prevention are added to Acas’s policy review process as an employer and procurer of goods and services.
• continuing to take action to embed a zero tolerance policy towards modern slavery.
• ensuring that staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices

Due Diligence

A&B Money undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. We take due diligence and reviews include with

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment];
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments through [the organisation’s own staff/third party auditor], which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• creating an annual risk profile for each supplier;
• taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through [third party auditor] and requiring them to implement action plans

Training

To ensure understanding of the risks of modern slavery and human trafficking in our supply chains and our business, all employees who are involved in procurement and supply chain management are required to complete mandatory training, relevant to the risks with modern slavery and human trafficking.

Performance indicators

A&B Money has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation is [select the relevant KPIs from the list below]:

• requiring all staff/staff working in UK/supply chain managers/HR professionals to have completed training on modern slavery.
• developing a system for supply chain verification in place. whereby the organisation evaluates potential suppliers before they enter the supply chain; and
• reviewing its existing supply chains, whereby the organisation evaluates all existing suppliers.

Awareness raising program

As well as training staff, the organisation has raised awareness of modern slavery issues by announcement on system for allow all level of employee able to access into the documents.

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking.
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• what external help is available, for example through the Modern Slavery Helpline.

Our effectiveness in combatting slavery and human trafficking

We remain vigilant in monitoring both the provision of our services and those we collaborate with to ensure we are effectively combating modern slavery and human trafficking.

Law relating in this document

Leading statutory authority

• Modern Slavery Act 2015
• Transparency in supply chains etc: a practical guide
• Stronger together initiative
• Ethical trading initiative
• Gangmasters Licensing Authority
• Global slavery index
• Business and human rights resource centre
• International Labour Organisation: forced labour, human trafficking and slavery
• Guiding principles on business and human rights: implementing the United Nations “protect, respect and remedy” framework

Section 54 of the Modern Slavery Act 2015 requires commercial organisations to prepare a slavery and human trafficking statement for each financial year of the organisation. The statement must set out the steps that the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business. If the organisation has not taken any such steps, it must still publish a statement to that effect.

Although s.54 of the Modern Slavery Act 2015 was brought into force on 29 October 2015, the requirement to prepare a slavery and human trafficking statement applies only to financial years ending on or after 31 March 2016. This means that an organisation with a financial year running from 1 April to 31 March must publish a statement for its 2015/16 financial year.

Section 54 states that the organisation’s statement may include information on:

• the organisation’s structure, business and supply chains (covered in Organisational structure and supply chains in this model statement);
• its policies in relation to slavery and human trafficking (covered in Relevant policies);
• its due diligence processes in relation to slavery and human trafficking in its business and supply chains (covered in Due diligence);
• the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps that it has taken to assess and manage that risk (covered in Organisational structure and supply chains);
• its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate (covered in Performance indicators); and

These headings are recommendations only and organisations may choose to set out their statement differently.

The duty applies to commercial organisations with a total turnover of at least £36 million per year. “Commercial organisations” that are covered by the duty are body corporates and partnerships that carry on a business, or part of a business, in the UK, supplying goods or services. See FAQs > Which employers are required to publish a slavery and human trafficking statement? for more details.

The slavery and human trafficking statement must be approved at the highest level of an organisation, for example by the board of directors, and signed by a director if the organisation is a body corporate, or approved by the members and signed by a designated member if the organisation is a limited liability partnership.

The organisation must publish the slavery and human trafficking statement on its website and include a link to the statement in a prominent place on the homepage. If it does not have a website, it must provide a copy of the slavery and human trafficking statement within 30 days of any written request for one.