Choose Wisely Limited (“the Company”)
Modern Slavery and Human Trafficking Statement.
Published on: 16th November 2017
This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1st May 2016 to 30 April 2017.
The statement sets down the Company’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains.
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. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
Although due to the qualifying turnover threshold the Act does not strictly speaking apply to the Company, it does carry on business with a number of organisations to whom it does. The firm has made the decision to disclose its statement regardless because of these relationships and because the team hold strong beliefs in opposition of slavery and human trafficking.
Organisational structure and supply chains
Choose Wisely Limited builds price comparison software and operates price comparison websites. Our head office is in Bournemouth on the south coast of the UK and we have approximately 30 employees, all of whom are based in the UK.
We operate through our brands, Choose Wisely Professional Tools and choosewisely.co.uk and we are committed to providing non-standard consumers with the safest tools, services and products they need to get access to vital credit and banking products.
The Company operates in the UK and on mainland Europe. Our supply chains include media agencies, online search engines, software suppliers and developers and professional service firms. We do not act as a producer, manufacturer or retailer of physical goods and have no supply chains in relation to such activities.
Over the course of the next year, The Company intends to adopt an Anti-Slavery and Human Trafficking Policy where we will confirm our zero-tolerance approach to modern slavery and which will reflect 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. This policy will become part of the existing Choose Wisely Code of Conduct & Ethical Standards Policy, which currently covers the Company’s policies on slavery and human trafficking.
These policies will be supported by the Company’s Whistleblowing Policy, which encourages and provides clear guidance on raising concerns in confidence relating to any wrongdoings and which will be extended to encompass slavery and human trafficking. All reports will be fully investigated and appropriate remedial actions taken.
The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
- Whistleblowing policy - the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
- The Employee Handbook - The code of conduct communicated in the Employee Handbook sets down the actions and behaviour expected of employees when representing the Company.
- Corporate Social Responsibility (CSR) Policy - The Company’s CSR policy summarises [how we manage our environmental impacts and] how we work responsibly with suppliers and local communities.
Assessment of Modern Slavery Risk within our Supply Chain
Over the course of the next year we will be increasing our focus on Modern Slavery, undertaking a risk assessment to determine where the risk of modern slavery and human trafficking lies both within the Company and in its supply chains.
All employees in the Company have their place of work at the offices leased by the Group. Our Operations team oversees the engagement and contracting process for these individuals and articulates the benefits available to employees via the handbook.
Suppliers will be assessed in terms of the nature of services they supply to the Company and any associated geographical risk. These assessments will cover the entire scope of our business, encompassing media agencies, online SEM, IT consultancies, PR agencies, HR consultants, building contractors, cleaning companies and other professional service providers. Geographically, most suppliers are based in the UK (or we contract with and make payment to the UK office) with the exception of some IT licence suppliers (namely Amazon Inc.). Our risk assessment has also highlighted the possibility that in service industries, particularly construction and cleaning, there could be the potential for workers to be put at risk of forced labour. We have categorised our suppliers as Category 1, Category 2 or Category 3 Risk Suppliers.
To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company plans to revise its employee handbook and train employees both on the revised handbook and the Company’s Anti-Slavery and Human Trafficking Policy. Training is provided to new employees as part of the induction process.
Due Diligence Processes for Slavery and Human Trafficking
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners. From 2018 onwards, the due diligence process will be revised to include evaluating the modern slavery and human trafficking risks of each new supplier and if appropriate, invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Chief Executive endorses this policy statement and is fully committed to its implementation.
Date: 16th November 2017