Modern Slavery & Human Trafficking
This statement is prepared for Digital Moneybox Limited pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out Moneybox’s approach to ensure slavery and human trafficking is not taking place in our supply chains, or any parts of our business. The Moneybox group is made up of five wholly-owned subsidiaries, none of which meet the threshold required to have its own modern slavery statement. This statement covers actions of the whole group.
We are committed to ensuring human rights standards, ethical practices, and meeting our responsibilities with regards to modern slavery. We do this through our own policies and practices, and by working with our suppliers, people and customers as set out below. Due to the nature of our business, our internal controls and the types of third parties we engage with, we have a low-risk exposure to modern slavery and human trafficking.
Suppliers & Third Parties
Moneybox works with a wide range of third parties ranging from small businesses through to multinational technology organisations, financial institutions and payment processors. We are committed to treating our third party relationships in a way that reflects our values, including the high standards we hold in relation to ethical practices.
- We identify and monitor risks associated with those third parties who pose a higher modern slavery or human trafficking risk due to the country in which they operate, or due to the services or products they provide. In order to work with these parties we require satisfactory completion of modern slavery due diligence.
- We undertake additional due diligence on our most critical and important third parties (irrespective of the country, industry or product risks) to confirm they adhere to our expectations on their compliance with legislative obligations, including in relation to modern slavery and any equivalent local legislation in the country in which they operate.
- We track, monitor and report internally on outsourcing and third party risks as per our risk appetite and tolerance to ensure a high standard is maintained with our critical and important third parties on an ongoing basis.
Our People
Moneybox’s workforce is mostly based in the UK. Our people are crucial to the successful delivery of our services and we ensure we uphold high standards of employment practices in an environment that is free from discrimination, harassment and any form of forced labour. We provide a range of benefits to our employees to ensure they have access to learning and development as well as physical and mental health support, and we commit to diversity, equity and inclusion in the way we run our business. Where we have workers based outside the UK, we ensure the arrangements comply with all applicable laws and regulations in relation to employment and ethical practices.
Our Customers
We want to ensure that our commitment to human rights and ethical practices is shared by those that use our products and services. Our terms of service give us the ability to block access to, freeze, or terminate, a customer account if a customer displays behaviour which is unacceptable to us including any breach of law or regulation.
Due to the nature of modern slavery and human trafficking, which can include using financial services to launder the proceeds of crime, our teams ensure appropriate due diligence is undertaken on all our customers at the point they sign up with Moneybox. We do not onboard any person as a customer that sits outside our risk appetite. We undertake ongoing monitoring to identify any potential financial crime risks and report appropriately through legal and regulatory channels where we suspect criminal activity. This would include those relating to human rights issues such as modern slavery and human trafficking, if identified.
Our Policies & Training
We have a number of policies that ensure ethical practices across our organisation, including:
- Company Handbook: This covers key employment rights and practices including bullying and harassment, reporting, and disciplinary matters.
- Speaking up Policy: This covers whistleblowing and reporting in relation to suspected wrongdoing or other dangers including criminal activity such as modern slavery, bribery, and financial terrorism.
- Disciplinary Policy and Procedure: This covers the reasonable steps we take when employees do not act in accordance with the high standards we set out in our organisation.
- Financial Crime Policy: This identifies risks of money laundering and terrorist financing, as well as fraud prevention obligations and staff training & competence.
We have mandatory training for all employees and contractors, to ensure that our high standards are being met, with training completion being monitored.
Forward Focus
We are committed to combating modern slavery and seek to continually improve our approach to monitor practices in our organisation and supply chains.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It was approved by our Board of Directors on 17 October 2024 and signed on its behalf by Ben Stanway on behalf of the Board of Directors [1].
Ben Stanway
Director and Co-Founder
Digital Moneybox Limited
[1] The signature on behalf of Digital Moneybox Limited on this annual statement made pursuant to the Modern Slavery Act 2015 is available on request from Digital Moneybox Limited’s Company Secretary, Suite 1.07 1-2 Hatfields, London, England, SE1 9PG
