Slavery and Human Trafficking Statement 2019

Introduction

As the leading employee engagement technology provider, Reward Gateway understands the importance of removing slavery and human trafficking from our global society – we live by our Think Global and Be Human values inside and outside of our business.

Our Mission “to make the world a better place to work” is one we take incredibly seriously and is at the forefront of everything we do. Modern Slavery is unacceptable within our business operations, and working with our teams and others to eradicate it is part of our overall approach to human rights and furthering our Mission.

We all have a responsibility to be alert to the risks, and everyone at Reward Gateway is expected to report concerns through the appropriate channels, with management acting upon them quickly and efficiently.

Our structure and background

Reward Gateway is a Software as a Service (SaaS) business that helps more than 1,900 of the world’s leading companies to attract, engage and retain their best people with an employee engagement platform that brings employee benefits, discounts and perks, reward and recognition, employee wellbeing, employee communications and employee survey tools into one unified hub.

Founded in 2006, we have over 400 people spread across four countries with offices in London, Birmingham, Sydney, Melbourne, Plovdiv, Boston and Rochester (USA). We are majority owned by Great Hill Partners, a private equity firm based in Boston, USA.

Our colleagues

Reward Gateway operates a rigorous recruitment selection process for all hiring decisions which includes obtaining documented proof of the individual’s right to work in the country in which they will be employed. We pay market wages, and will always pay colleagues at least the minimum wage rate applicable in the geography in which they work.

We are passionate about doing business the right way, and all of our colleagues are required to demonstrate the highest ethics. All colleagues are guided by the eight values which we share, and these shape how we think, plan and make decisions to deliver operational excellence and best serve our customers.

1,800+ clients Trust us with their employee engagement	1,900+ retailers Partner with us	£636 million Retail spend was handled by us in 2018.
430k transactions Are processed by us every month	5 million Employees are actively using our tech	£225 million+ Total employee savings up to May 2019

Our stance towards slavery and human trafficking

Given the nature of our business, it continues to be our view that the risk of modern slavery in our supply chain is low compared to businesses operating in other sectors. However, we do not intend to be complacent and will continue to work to improve our policies and procedures to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.

How we ensure our stance

Speak Up – Reward Gateway encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains, of the business. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The reporting process is designed to make it easy for workers to make disclosures, without fear of retaliation. Those who have concerns can raise them via their line manager, the People team or by emailing compliance@rewardgateway.com. Over the past year, nobody has raised any such concerns with us.

Staff Handbook – Reward Gateway’s handbook makes clear to employees the actions and behaviour expected of them when representing the organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour both in the UK and when operating abroad and when managing our supply chain.

Procurement – Reward Gateway is committed to ensuring that our retail partners adhere to the highest standards of ethics and we only partner with reputable companies to ensure this.

Agency workers policy – Reward Gateway uses only specified, reputable employment agencies to source labour and we always verify the practices of any new agency we are using before accepting workers from that agency.

Our supply chain

Whilst we resource our core services including engineering in-house where we have full control, like most large businesses we have a large supply chain, especially in the fulfillment part of our benefits and rewards products. Our suppliers are split into two categories; retailers who we partner with to deliver our benefits and reward products to our customers; and direct suppliers who provide a variety of products and services used by our teams across the globe.

Retail partners and suppliers

Whilst almost all of our direct suppliers are in countries where the risk of slavery and human trafficking is low, we are conscious that the 1,900+ retailers that we work with globally have their own complex supply chains that are in higher risk areas.

We have begun the process of vetting our existing 1,900+ retailers to ensure they are compliant with the Modern Slavery Act 2015 and aligned with our own standards. Along with monitoring our existing partnerships we are reviewing our onboarding process to include relevant assurance questions about Modern Slavery to ensure future partners are compliant.

We continue to monitor industry and consumer news to be alert to modern slavery within the retail space. If and when we are made aware of any serious human rights violations within our partner network, we will act quickly and proportionally. Over the past year, we have not identified or been made aware of any of our supply chain partners who have fallen below our standards.

Direct suppliers

We partner with Fair Trade accredited suppliers for many of the products used in our offices. Many of these businesses have been chosen not only because of their focus on treating people in their supply chain fairly, but also because of their alignment with our Mission. Examples include:

Change please - A social enterprise coffee supplier that provides barista training to homeless people.
Who Gives a Crap - A social enterprise toilet paper supplier that donates 50% of revenue to building toilets in developing countries.
Soap Co - A social enterprise soap supplier who provide working opportunities to people who are blind, disabled or otherwise disadvantaged.

As we continue to improve our supplier network, we foresee more opportunities to partner with innovative suppliers who share our values and can in fact act help us in achieving our Mission.

What actions have we taken in the last 12 months?

Retail Team

Raised awareness that we need more support in understanding how to mitigate risk and monitoring Modern Slavery Statements of UK retail partners with £1mil+ turnover
Respond to alerts in a measured and appropriate way.

Wider Team

Hosted internal events to raise internal awareness of Modern Slavery.
Volunteered our skills to charities who work to eradicate Modern Slavery.
Partnered with Fair Trade accredited, direct suppliers, some of whom are absolutely aligned with our Mission.

Partnerships

Provided a platform for ‘front line’ organisations who are addressing Modern Slavery and Human Trafficking to connect with and educate our clients, HR network, and employees.
Provided grant funding through RG Foundation to organisations who are on the front line in addressing Modern Slavery.
Provide our employee engagement products at zero cost to a number of small charities who are on the front-line in the fight against Modern Slavery.

Looking ahead

Over the next 12 months, we will continue to build on our current approach to managing the risk of slavery and human trafficking within our business. Our ambitions include:

Publishing our Social Value Strategy 2020 which will outline our overall approach to our commitment to community impact and how that relates to our commercial strategy.
- The strategy will outline 5 core elements that will guide our work in this space from 2020 and beyond.
- Each element is framed by a goal, objectives and targets and is related to one or more of the United Nations Sustainable Development Goals.
- Our objectives with regards our approach to eradicating Modern Slavery sit within element no.3 - “building sustainable value for our Clients and Suppliers.
Partnering with a third party organisation to provide tailored training to our Retail Team to help support their efforts to reduce the risk of Modern Slavery within our retail partners supply chains, and set out a 3 year roadmap for reducing risk in our business.
Create a step by step process which outlines our response if we are alerted that one of our suppliers is engaging in acts that constitute Modern Slavery.
Reviewing and revising our policies and processes to include express reference to the Modern Slavery Act.
Continue to support small charities who are on the front-line of eradicating Modern Slavery through our own products/services, amplifying their voice internally and externally and through financial contributions.

Assessment of effectiveness in preventing Modern Slavery

We understand that the Modern Slavery risk is not static, and we will continue our leading approach to mitigating this risk in the year ahead.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Reward Gateway statement on the prevention of slavery and human trafficking for the financial year ending 30 June 2019. It has been approved by our board who will review and update it annually.

Signed and approved by:
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Doug Butler
CEO - Reward Gateway