Modern Slavery and Human Trafficking Policy
This is the Modern Slavery and Human Trafficking Policy of The Voucher Market Limited, trading as WeGift UK Limited (WeGift). This policy sets out WeGift’s actions to understand all potential modern slavery risks related to its business, and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in its business and its supply chains. This statement relates to actions and activities during the financial year ending 2020.
What is modern slavery?
Modern slavery encompasses all types of slavery, human trafficking, servitude, and forced or compulsory labour across a vast number of industries. Modern slavery may affect individuals that are resident within or outside of the United Kingdom.
Why do we need to make a statement?
We publish this statement in compliance with the UK Modern Slavery Act of 2015 to show our users how we prevent modern slavery, human trafficking, forced labour, and labour rights violations from taking place in our business and supply chains. While WeGift takes similar steps globally, this statement applies to WeGift UK Limited.
WeGift is a global technology company that builds economic infrastructure for the business-to-consumer payouts industry. Businesses of all sizes use our services to send the people they care about incentive payouts and manage their businesses online. Our goal is to build a world where everyone can access the global economy without barriers, banks, borders, or boundaries. Our global headquarters is in London, England, and we have regional offices in the United States. We enable our customers, who are located in more than 26 countries, to send incentives to recipients anywhere in the world.
At WeGift, we strive to always do the right thing in our business operations, including complying with applicable laws and maintaining the highest ethical standards. We take a zero-tolerance approach to slavery and human trafficking, and any other illegal or unethical conduct. This commitment is supported by our corporate policies, including our Whistleblowing Policy, which encourages employees and workers at all levels to report suspected illegal or unethical conduct, and provides guidance as to how to raise such concerns; and our Anti-Bribery Policy, which sets out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption.
In addition, all our employees and workers are expected to behave in accordance with our WeGift Code of Conduct. This requires them to establish and maintain ethical standards and raise any suspicions of unlawful or unethical conduct to their direct manager. These policies are in line with our core business values of “Build Trust” and “Dive Deep” so that we act with honesty, rigor, integrity, transparency, respect, and in a socially responsible manner.
We operate the following policies that describe our approach to the identification of modern slavery risks, and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing Policy. We encourage our staff, customers, and business partners to report any concerns related to the direct activities, or the supply chains, of our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our Whistleblowing Policy is designed to make it easy for workers to make disclosures without fear of retaliation. Employees, customers, or others who have concerns can speak to the People Team or complete our confidential disclosure form document in the full Whistleblowing Policy.
- Employee Code of Conduct. Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing supply chains. The full Employee Code of Conduct is documented here.
- Our supply chain. The majority of WeGift’s suppliers are based in Europe and North America. We perform due diligence on our suppliers before signing with them, including reference checks. We are committed to ensuring that our suppliers adhere to the highest standards of ethics. We will not knowingly support or do business with any organisation that is involved in such practices and we would seek to terminate any relationship immediately where evidence of the same occurred, report the activity to law enforcement, and cooperate with any resulting investigation.
- Recruitment policy. We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency.
Training at WeGift
In 2021, we will roll out an annual, mandatory training for all employees on financial crimes and human trafficking. This training will inform employees about the high-level red flags of financial crimes and human trafficking, and will provide clear escalation paths to ensure any suspected financial crimes issues are properly reviewed and investigated.
WeGift is committed to maintaining an understanding of global legal developments relating to human rights and modern slavery, so we can continue to operate responsibly and in compliance with the law. We will continue to monitor how we receive and provide services to ensure that we are effectively combatting the risk of modern slavery in our business.
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act of 2015.
This statement has been approved by The Voucher Market Limited’s board of directors.