This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Stonebridge Payment Solutions Limited (“Stonebridge”) has taken and is continuing to take to ensure that modern slavery and human trafficking is not taking place within its business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Stonebridge have a zero-tolerance approach to any form of modern slavery and is committed to acting ethically and with integrity and transparency in all business dealings.

 

Our Business

 

The GDPR defines personal data as: “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

 

Our Policies on Modern Slavery and Human Trafficking

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Our business is built around compliance and it is at the centre of all the services we offer and how we operate. Our industry is highly regulated with many HMRC rules, employment laws and tax regulations to adhere to. We retain the services of leading tax and employment law specialists to ensure our continuing compliance with relevant legislation.
We operate a robust recruitment policy, including conducting eligibility to work in the UK checks on all workers to safeguard against human trafficking or individuals being forced to work against their will.
We conduct due diligence on all workers before entering into any contractual arrangement. This due diligence includes:
 

• Completing a Right to Work check, ensuring that workers do have valid Right to Work in the UK.

• Ensuring all workers are paid into their own bank account. We offer the opportunity to have their payment made into a nominated account for a limited time if we are happy with the reasons. We will always obtain consent from both the worker and the nominated account holder.

• Ensure all limited company contractors have their payments made into a business bank account.

• Undertake checks on limited company contractors so we are aware of their business structure and whether they engage any workers themselves.

 

Our Supply Chain

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Our supply chain includes the subcontractors and workers we engage to work on assignments for our recruitment agency clients. We aim to build strong and long-lasting relationships with our clients and make them aware of the expectations we have of them regarding business behaviour.

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Training

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All internal members of staff are trained and provided with guidance on modern slavery and human trafficking, including how to spot signs of it and what to do if they suspect that it is taking place within our supply chain.

 

Approval for this Statement

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This statement was approved by the Chief Executive Officer.

David O’Sullivan

CEO Stonebridge