Reward Gateway Slavery and Human Trafficking Statement 2024

Introduction

This statement outlines our global approach to modern slavery and human trafficking and is made pursuant to section 54(1) of the Modern Slavery Act (2015) in the UK and in respect of Reward Gateway Pty Limited (ACN 141 363 564) in Australia, the Modern Slavery Act, 2018 (Cth).

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 ‘We Are Human’ values inside and outside of our business.

Our Mission “to make the world a better place to work” is one we take 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.

Quick Stats

Structure

Reward Gateway is a Software as a Service (SaaS) business that helps more than 4,000 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.

Reward Gateway is now part of the wider Edenred Group. Edenred is a publicly listed CAQ40 organisation with headquarters in Paris, France.

Below is a list of our 6 global trading entities, along with their company numbers, registered addresses, and employee headcount as of 1st January 2024 (beginning of reporting financial year).

Operations

Founded in London in 2006, we employ 900+ people spread across 4+ countries with offices in London, Sydney, Melbourne, Plovdiv, Sofia, Boston and Rochester (USA). Our Global Leadership Team is responsible for all operations within our Group. You can find out more about our Leadership Team here.

Our People

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-rate 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 expected to demonstrate the highest ethics. All colleagues are guided by our Mission, organisational values and our eight fundamental behaviours, which we share. Our values shape how we think, plan and make decisions to deliver on our Mission and best serve our customers.

Our Employee Handbook

The Reward Gateway Employee Handbook (rg.co/employeehandbook) is issued to every employee when they join the business and is a point of reference for all our People regarding our Mission, culture, behaviours, policies and processes.

The Employee Handbook lays out our zero tolerance on bullying through our Anti-Bullying and Harassment Policy; our commitment to conducting business in an open and ethical way through our Anti-Fraud and Anti-Bribery Policy; and how and what we encourage employees to disclose to management through our Whistleblowing Policy.

Supply Chain

Whilst we resource our core services – including engineering – in-house, where we have full control and visibility, 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:

1. Retailers who we partner with to deliver our benefits and reward products to our customers;
2. Direct suppliers who provide a variety of products and services used by our teams across the globe.

Retail Partners

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 2,500+ retailers that we work with globally have their own complex supply chains that involve higher risk areas.

We began the process of vetting our existing partners in 2020 and, currently, the majority of our 2,500+ retailers are compliant with the modern slavery legislation where we operate and align with our own standards. In addition, our top 200 retail partners, based on popularity, go through our vetting process annually. Along with monitoring our existing partnerships, we have a robust onboarding process that includes 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. During the Financial Year for which this statement refers, we did not identify any of our retail partners who have fallen below our standards.

Direct suppliers

Given the nature of our business, our direct supply chain mostly consists of service providers and the procurement of other software-related goods and services to aid our operations and empower our People. We source goods and services from reputable suppliers and the nature of the goods and services we procure do not demand the types of labour at risk from slavery and human trafficking.

Service providers that we rely on (mostly digital) to operate are chosen primarily by the individual teams who are responsible for implementing them and managing the ongoing relationship. We have no central procurement department, however we have a centralised Information and Security team who ensure compliance with GDPR and other security and supplier standards.

You can find out more about our Security Standards, as well as other direct supplier standards, at rg.co/security.

The physical products we procure are minimal because of the nature of our business. All of our staff use technology products in order to fulfill their job roles and stay connected with the business. All of the technology products we procure are from reputable, global businesses.

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:

• Grumpy mule - An independent coffee supplier that supports education for children and women’s rights in developing countries.
• 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 that provides 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 help us in achieving our Mission, and in 2024, we introduced our Supplier Charter of Ethics that we ask all of our suppliers to acknowledge.

Risks of Modern Slavery

Risks that we may cause Modern Slavery practices

We have identified a low risk of modern slavery practices within the operations of our business. The majority of our workforce is made up of highly skilled people who are direct employees and therefore undergo an internal and thorough recruitment process before joining our business. Once an employee has joined the business, their information is gathered and managed through a centralised HR platform.

Any recruitment agencies we choose to partner with match our own ethical and quality standards and undergo a verification process before we partner with them. However, we understand that as they are not directly part of our business, there is a risk that they may be in breach of modern slavery practices without our knowing.

A small percentage of our workforce are hired on temporary contracts. However, these roles are for professional service contracts and will be subject to contract terms and conditions that comply with local labour laws. We don’t employ seasonal or casual workers and are in the process of renewing our UK Living Wage employer accreditation.

Risks that we may contribute to modern slavery practices

The largest area of risk that we have identified that may contribute to modern slavery practices is the relationships we have with our 2,500+ Retail Partners. Many of the retailers we partner with are through direct relations with their in-house partnerships teams, and others are through Affiliate Networks who we partner with.

Each of the retailer partners that we work with has their own supply chain, and as many of them are global organisations, their supply chains can be incredibly complex and exist in countries where the risk of human rights abuses is high.

There are also smaller retailers we partner with that will not be legally required to comply with modern slavery laws, and which therefore are more difficult to assess as a risk due to a lack of transparency.

Risks that we may be directly linked to modern slavery practices

We’ve identified relatively low risk through the other organisations in our supply chain and which we have relationships with. The main risk lies within our direct supply chain and the businesses that we procure technology products from. They are global businesses that source some of their raw materials from countries with a higher risk of human rights abuses.

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 operations, and that the businesses we choose to partner with understand our stance.

We have zero tolerance of slavery and human trafficking.

We expect all those in our supply chain and contractors to adopt the same approach and, at the very minimum, to be compliant with the Modern Slavery Act 2015 (UK) and the Commonwealth Modern Slavery Act 2018 in Australia.

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. We also have a dedicated channel on our internal instant messaging platform (Slack) to report risks and potential incidents of modern slavery violations.

Employee Handbook | Reward Gateway’s handbook makes clear to employees the actions and behaviours 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 abroad, and when managing our supply chain. 

Procurement | Reward Gateway is committed to ensuring that our retail and other partners adhere to the highest standards of ethics and we only partner with reputable companies to ensure this. Our retail team keep an updated record of ‘high risk’ retail partners to ensure their compliance with modern slavery legislation.

Agency workers | Reward Gateway uses only 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.

Social Value Strategy 2024 | Reward Gateway’s Social Value Strategy 2024 is a framework to help us operate as a more sustainable business. Aligned with the Edenred CSR Strategy, it has three core pillars (People, Planet & Process) all related to one or more of the United Nations Sustainable Development Goals.

CSR/ESG Correspondants | This is a group of colleagues across Reward Gateway who are responsible for developing and delivering our Social Value Strategy and ensuring our CSR KPI’s are achieved. Our Correspondents are responsible for all of our CSR Reporting and ensuring our compliance with Modern Slavery legislation in the countries that we operate. The team regularly reports back to Edenred HQ in Paris.

Events and networks | Reward Gateway has a large network of employers and HR leaders. Through our events and content, we are able to raise the profile of organisations we support, as well as the importance of modern slavery awareness.

Our products and technology | Reward Gateway’s engagement platform can be used by our clients to communicate anything they like with their employee base. We use ours internally to raise awareness of modern slavery amongst our teams, and we provide our products to small modern slavery charities free of charge.

What actions have we taken in the last 12 months?

Retail Team

1. Continued to monitor retailer partners with £1mil+ turnover to ensure their compliance with the UK’s Modern Slavery Act (2015) and the Commonwealth Modern Slavery Act 2018 (Cth) in Australia.
2. In 2020, our Global Retail Team undertook modern slavery awareness training with the Slave Free Alliance. The training was designed to improve general knowledge of modern slavery, as well as provide some practical tools for working with supplier partners. Since then, the team has continued to improve their knowledge and understanding of modern slavery issues and, most recently, initiated awareness conversations about greenwashing.
3. Established a vetting process for “green” retailers,  ensuring they have the relevant certifications and targets in place.
4. Further established and updated our incident reporting process, which was created in 2021 through interactions with a retail partner that had been accused of breaching modern slavery legislation.

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:

• Develop and publish our Social Value Strategy 2025, including objectives to progress our modern slavery agenda.
• Clarify our whistleblowing process for reporting incidences of modern slavery for all stakeholders related to our business.
• Complete a training ‘needs assessment’ in regard to modern slavery awareness at different management levels across the business.

Assessing the effectiveness of these actions

We understand that the modern slavery risk is not static, and we will continue improving our approach to mitigating this risk in the year ahead. The actions that we are taking to assess the effectiveness of our approach are:

1. Continuing our annual review of our Modern Slavery Statement.
2. Continue to monitor and report on any incidents of alleged breaches of modern slavery practices.
3. Continue to look for opportunities to increase awareness on modern slavery amongst our Leaders and our People through training and conversations.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 in the UK and the Commonwealth Modern Slavery Act 2018 in Australia, and constitutes the Reward Gateway statement on the prevention of slavery and human trafficking for the financial year ending 31 December, 2024. 

It has been approved and endorsed by the board of directors of Reward Gateway UK Limited (company number 05696250) and Reward Gateway Pty Limited (ACN 141 363 564). 

Signed and approved by
Nick Burns
Chief Executive Officer

Past versions of Slavery and Human Trafficking Statements:

The 2022-2023 Slavery and Human Trafficking Statement from Reward Gateway

The 2021 Slavery and Human Trafficking Statement from Reward Gateway

The 2020 Slavery and Human Trafficking Statement from Reward Gateway

The 2019 Slavery and Human Trafficking Statement from Reward Gateway

The 2018 Slavery and Human Trafficking Statement from Reward Gateway

The 2017 Slavery and Human Trafficking Statement from Reward Gateway