Modern Day Slavery Statement

Everyone has the right to work in an environment where they are treated with respect.

Our policy on anti-slavery and human trafficking explains our commitment to ensuring our supply chain is free from modern slavery and the actions we’ve taken to understand potential risks in relation to our business.

Introduction

This statement sets out ParentPay Group’s actions to understand potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business or our supply chains.

We recognise that we have a responsibility to take a robust approach to slavery and human trafficking. We are fully committed to preventing slavery and human trafficking in our business activities, and to ensuring that our supply chains are free from slavery and human trafficking.

Modern slavery

“Modern slavery” refers to the offences of human trafficking, slavery, servitude, and forced or compulsory labour.

“Human trafficking” involves the recruitment, transfer or obtaining of an individual through coercion, abduction, fraud or force to exploit them. There are several broad categories of exploitation linked to human trafficking, including sexual exploitation, forced labour, domestic servitude, organ harvesting, child related crimes, forced marriage and illegal adoption.

Modern slavery is an international crime affecting millions of individuals globally, an issue that transcends age, gender and ethnicities. Modern slavery includes victims who have been brought from overseas and vulnerable people in the UK who are forced to work illegally against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing.

Our Group

ParentPay Group consists of including UK operating companies: ParentPay Ltd; Nimbl Ltd; Just Education Ltd; Just Education Recruitment Ltd; and Education Software Solutions Ltd, each of which sits under our group parent company ParentPay (Holdings) Ltd. In addition, we have operating companies in the Netherlands and in Germany, with the group employing a total of approximately 300 staff across Europe.

Our Supply Chain

We have a supply chain of around 100 suppliers, the majority of which are based in the UK (for example for payment processing, hosting and consultancy) or in the US (in the case of software tools used by the group). We also have offshore software development partners in Sri Lanka and Moldova.

Our policy

ParentPay Group’s policy is to conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation. We strive to ensure that there is neither modern slavery nor human trafficking in our supply chain or in any part of our business.

Our internal and external policies and procedures reflect our commitment to these objectives and to enforcing appropriate systems and controls which aim for a zero-tolerance approach to anti-slavery and human trafficking laws.

ParentPay Group has created a dedicated Anti-Slavery and Human Trafficking Policy. We will review this policy and its operation in practice, at least on an annual basis.

Supply chain/ Procurement

We acknowledge that our business is exposed to a greater slavery and human trafficking risk when dealing with suppliers of products and services, particularly those who have operations and suppliers in other regions overseas.

We consider that as the majority of our suppliers are not in industries with a high risk of modern day slavery and our supply chains is primarily confined to the UK, we have a relatively low risk of modern day slavery and human trafficking occurring within our supply chain.

We have adopted a risk-based approach to identifying and reviewing suppliers and vendors that fall within industries and/or countries that can carry higher risk. We are developing measures to assist in the review and management of these areas of risk, including a supplier on-boarding and selection process, as well as ongoing monitoring.

The processes and systems are intended to:
• identify and assess potential risk areas in our supply chains;
• mitigate the risk of slavery and human trafficking occurring in our supply chains;
• monitor potential risk areas in our supply chains; and
• protect whistle blowers.

Reporting knowledge or suspicion of slavery or human trafficking

All employees have an obligation to report knowledge or suspicion of slavery or human trafficking. The ParentPay Group Whistleblowing Policy provides for alternative avenues for reporting, including in respect of suspicion or knowledge of slavery or human trafficking.

Employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal.

Where statutory reporting requirements and procedures exist, these must be fully complied with.

Employees requiring guidance are encouraged to visit the UK Modern Slavery Helpline, via their website at https://www.modernslaveryhelpline.org/.

Employment procedures

We have procedures in place as part of our recruitment processes in line with UK employment law (as applicable), including “right to work” document checks, contracts of employment, and checks to ensure all employees are above minimum working age (16).

Supplier Adherence

We have zero tolerance to slavery and human trafficking. To ensure our supply chain complies with our standards, we are implementing processes to:
• communicate our expectations to our supply chain in respect of sustainability, anticorruption and bribery and ethical procurement;
• encourage our suppliers to cascade similar expectations within their own business and supply chain;
• ensure adherence to our policies at supplier selection, on-boarding and ongoing risk management; and
• ensure that adherence to our policies is a contractual obligation in our agreements with suppliers.

Awareness Training

We want to help our employees, clients and suppliers understand the issues and risks, and how to report any suspicions they may have.

Our Anti-Slavery and Human Trafficking Policy is highlighted during induction training and we flag any update of this Statement and associated policies to all staff members.

We are continuing to develop training on slavery and human trafficking to be delivered to relevant employees on a periodic basis.

Related policies and documents

The Whistleblowing Policy encourages employees to raise concerns or disclose information, which relates to wrongdoing, illegal practices or unethical conduct, which may come to their attention.

In addition to the Whistleblowing and the Anti-Slavery and Human Trafficking Policies, ParentPay Group has a number of related policies and documents which reflect our objective to act honestly and ethically and in line with legal and regulatory obligations.

These include:
• ParentPay Group Safeguarding Policy
• ParentPay Group Ethical Purchasing Policy
• ParentPay Group Anti-Corruption and Bribery Policy

These policies and documents will continue to be reviewed on, at minimum, an annual basis.

Monitoring Our Effectiveness

We use the following KPIs to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains

• New staff are inducted on our Anti-Slavery Policy
• Suppliers with a turnover of more than £36 million are requested to provide us with a copy of their Modern Slavery and Human Trafficking Statement
• Higher risk suppliers are issued with our Anti-Slavery Policy and requested to provide a written confirmation that they comply

Higher risk suppliers are those providing personnel or with overseas operations in potentially ‘high risk’ regions.

Looking forward

ParentPay Group will continue to develop and implement the measures outlined above in respect of our supply chain and we will continue to mitigate the risks of modern slavery and human trafficking through the provisions detailed in this statement on an ongoing basis.

This statement and its objectives will be reviewed and updated as appropriate.

During the financial year ended 30 November 2021 the ParentPay Group Board did not receive any reports which relate to knowledge or suspicion of slavery or human trafficking

This statement has been approved by our board, who will review and update it annually.

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