Modern Slavery Act Transparency Statement for Edenred (UK Group) Ltd.

OPENING STATEMENT FROM THE DIRECTOR HUMAN RESOURCES

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the steps the Company has taken during the financial year from 1 January 2020 to 31 December 2020 to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.

Slavery and human trafficking is a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Our colleagues are expected to report concerns and management are expected to act upon them.

Edenred (UK Group) Ltd is dedicated to preventing modern slavery and human trafficking from taking place within its business and supply chain. We adopt a zero-tolerance approach to slavery and human trafficking in all forms throughout the organisation, which extends to our supply chains. This includes rigorous employment vetting and due diligence when selecting and approving suppliers. As part of our zero-tolerance approach, any risk with a supplier will result in no further work being offered to related suppliers.

OUR COMMITMENT

We are committed to ensuring that there is no slavery, servitude, forced or compulsory human labour, abuse of power over vulnerable individuals, human trafficking or any other form of exploitation as contemplated by the Modern Slavery Act 2015.

STRUCTURE AND SUPPLY CHAINS

Edenred (UK Group) Ltd is a wholly owned subsidiary of Edenred SA, France. The Edenred Group is the world’s leading provider of prepaid services. Edenred’s business base is spread evenly among developed and emerging markets. Edenred (UK Group) Ltd employs circa 180 people in the UK; the following weblink provides more information regarding the nature of our business www.edenred.co.uk.

The nature of our business requires that we work in conjunction with a range of affiliates, suppliers and partners and we uphold the expectation to commit to all relevant legislation with all our suppliers.

OUR POLICIES RELATING TO SLAVERY AND HUMAN TRAFFICKING

As reported in our previous statements, Edenred (UK Group) Ltd’s internal policies include our Anti-Slavery and Human Trafficking Policy where we confirm our zero-tolerance approach to modern slavery; and which 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 is not taking place anywhere in our supply chains.

These policies are supported by our Whistleblowing Framework, which encourages and provides clear guidance on raising concerns in confidence relating to any wrongdoings which extends to slavery and human trafficking. Our Whistleblowing Framework is supported by an external, confidential reporting hotline which enables employees of the Group to raise concerns in confidence. All reports received via our Whistleblowing Framework will be fully investigated and where appropriate, remedial actions taken.

The following further policies exist within our organisation, which demonstrate our opposition to modern slavery:

  • Edenred Charter of Ethics.
  • Edenred Group Corporate Social Responsibility Global Statement as part of part of the Edenred Group Registration Document.

A copy of these polices are available on www.edenred.com We ensure that relevant suppliers are aware of the relevant policies pertaining to the product area/service provided and encourage them to adopt the same high standards.

DUE DILIGENCE PROCESSES RELATING TO SLAVERY AND HUMAN TRAFFICKING

As part of our efforts to monitor, manage and reduce the risk of slavery and human trafficking occurring within our business or supply chains, we adopt the following due diligence procedures:

  • Identify, monitor and manage areas of potential risk in our business and supply chains.
  • Scrutinise any identified areas of risk within our business and supply chains.
  • Provide support and protection from detriment or disadvantage to any person who, in the public interest, raises genuine concerns amounting to a protected disclosure.
  • Rigorous Employment Vetting.
  • Due Diligence on all suppliers.
  • Obligations to Partners to comply with all relevant legislation.

RISK AND COMPLIANCE

Our organisation regularly evaluates the nature and extent to which our business and our supply chains are exposed to the risk of modern slavery occurring. The following list of risk management activities and procedures demonstrates our commitment to compliance:

In the UK, we do not consider that we operate in high risk sectors or locations. Where we have identified a potential risk, we prioritise this risk and take appropriate action to put remedial measures in place. No further work would be offered to related suppliers, following discussions of apparent related acts/omissions by the supplier. A copy of our employment vetting procedure is available on request and subject to a non-disclosure agreement.

KEY PERFORMANCE INDICATORS (KPIs)

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains: 

  • Vendor partner(s) audits which are inspected by Edenred Group annually for verification
  • Use of labour monitoring and payroll systems; and
  • Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.

In order to assess the effectiveness of the measures taken by Edenred UK we are, or will be reviewing:

  • Investigations undertaken into reports of modern slavery (including any concerns raised under our Whistleblowing Framework) and remedial actions taken in response; and
  • Staff training levels, including a review of the current Code of Conduct training.

TRAINING

We ensure all employees and Directors are aware of the risks of modern slavery and human trafficking in our business and supply chains. All Employees are required to complete refresher training covering our Code of Conduct and Human Trafficking Policy on an annual basis.  Training is provided to new employees as part of their induction.

FURTHER STEPS

We will continue to undertake training of employees, particularly those directly involved in engaging suppliers, to ensure they understand and comply with the supplier contract management framework.


 
Alisdair Seenan - HR Director - Edenred (UK Group) Ltd.

Modern Slavery Act Transparency Statement

Issue Number: 6

Issue Date: 07/06/2022