Modern slavery statement
Fintrax and its associated companies operate an ethical and open approach to the way it does business. The company does not tolerate any form of unethical behavior. Modern slavery is criminal activity and a violation of human rights. The deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain is unacceptable. For these reasons, slavery and human trafficking, including forced labour and unlawful child labour, are a matter of zero tolerance for the company.
The company recognises it has a responsibility to take a robust approach to slavery and human trafficking. Following the implementation of the Modern Slavery Act 2015 in the UK, the company is committed to maintaining and enforcing effective systems and controls to prevent slavery and human trafficking, within its corporate activities.
Human trafficking and slavery are crimes under UK and international law. These crimes exist in countries throughout the world. This policy statement defines the company’s commitment to ensuring human trafficking and slavery does not exist within its own business. It also defines how the company will make efforts to eradicate it from other businesses with whom it maintains a relationship, and from within its supply chain.
This policy applies to all individuals employed by Fintrax and its subsidiary and affiliated companies (referred to as Fintrax or the Company in this policy) including directors, employees, including part-time and fixed term employees (referred to as staff or employees in this policy) and to interns and work experience students, temporary and agency staff and Contractors and Consultants (referred to as associates in this policy).
Human trafficking: the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability. Or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.
Forced labour: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.
Harmful child labour: consists of the employment of children which is economically exploitive, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral or social development.
Responsibility for reporting incidents of slavery
The detection and reporting of slavery is the responsibility of all employees. Employees should raise any concerns about any issue or suspicion of modern slavery in any part of the company’s business or supply chain at the earliest possible stage. Suitable channels of communication by which an employee can report confidentially, any suspicion of slavery, are detailed in the Fintrax Whistleblowing procedure.
Right to work checks
The company will conduct ‘right to work’ checks on every employee within its employment. The company expects all of its supply chain to perform the same checks in accordance with the Immigration, Asylum and Nationality Act 2006.
Requirements for Suppliers
The company expects its suppliers:
- Will not use forced or compulsory labour, i.e. - any work or service that a worker performs involuntarily, under threat of penalty;
- Will ensure the overall terms of employment are voluntary;
- Will comply with the minimum age requirements prescribed by applicable laws;
- Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements;
- Will abide by applicable law concerning the maximum hours of daily labour;
- Will not engage in any practice of slavery, servitude, forced labour, compulsory labour and/or human trafficking outside the UK which would constitute an offence if that conduct took place within the UK; and
- Will ensure that any sub-contractors or suppliers from whom they source goods and/or services for incorporation in those supplied to Fintrax, also adhere to these requirements.
Suppliers will certify compliance with this policy and their adherence to relevant human trafficking and slavery laws in each of the relevant countries in which they operate.
Suppliers who are found to be engaged or to have engaged in human trafficking and slavery or which refuse to co-operate with any audit to verify compliance with his policy, will be liable to have any supply agreement, arrangement or other contract with Fintrax, terminated immediately, without compensation.
Breaches of the policy
The company commits to taking all necessary steps to ensure both its workforce and suppliers engagement are free from the effects associated with modern slavery, human trafficking, and forced or bonded/imprisoned labour.
Any reported breach of this policy will be investigated and may lead to legal proceeding or disciplinary action, which subsequently could result in employee dismissal.
This policy replaces any previously published policy on this subject. This policy is for internal use only and should not be distributed outside Fintrax without written consent from the Policy Owner. This policy will be periodically reviewed. Any amendment to it and the effective date of the amendment will be notified to employees by the Company's HR Department. This may be by means of the Company's intranet or via use of notice boards.