Modern Slavery and Human Trafficking Policy


Pay Hive Limited

Effective Date: 26/05/2022
Review Date: 01/01/2026


1. Policy Statement

Pay Hive Limited is committed to preventing modern slavery and human trafficking in all aspects of our business and supply chain.

We have a zero-tolerance approach to modern slavery and are committed to acting ethically, transparently and with integrity in all our business relationships.

We expect the same high standards from our employees, contractors, recruitment agencies, suppliers, business partners and any other organisations with whom we work.


2. Purpose

The purpose of this policy is to:

  • Prevent modern slavery and human trafficking within our business.
  • Ensure compliance with the Modern Slavery Act 2015.
  • Promote ethical employment practices.
  • Protect the rights and wellbeing of workers.
  • Ensure concerns can be raised safely and investigated appropriately.


3. Scope

This policy applies to:

  • Directors
  • Employees
  • Agency workers
  • Contractors
  • Consultants
  • Temporary workers
  • Recruitment agencies
  • Suppliers
  • Service providers
  • Business partners

Everyone associated with Pay Hive Limited is expected to comply with this policy.


4. What Is Modern Slavery?

Modern slavery is a crime and a violation of fundamental human rights.

It can take many forms, including:

  • Human trafficking
  • Forced or compulsory labour
  • Debt bondage
  • Servitude
  • Slavery
  • Child labour (where illegal or exploitative)


Victims may be coerced, threatened, deceived or exploited for financial or personal gain.


5. Our Commitment

Pay Hive Limited is committed to:

  • Operating lawfully and ethically.
  • Treating all workers fairly and with dignity.
  • Paying workers correctly and on time.
  • Complying with UK employment legislation.
  • Respecting human rights.
  • Working only with reputable recruitment agencies and suppliers.
  • Taking appropriate action where concerns arise.

We will not knowingly engage with organisations involved in modern slavery or human trafficking.


6. Risk Assessment

As a payroll umbrella company, we recognise that risks may arise through:

  • Recruitment supply chains.
  • Labour providers.
  • Identity fraud.
  • Right to Work documentation.
  • Temporary labour arrangements.
  • Third-party service providers.

We regularly review our business relationships and procedures to reduce these risks.


7. Due Diligence

To help prevent modern slavery, we may:

  • Verify the identity of workers.
  • Carry out Right to Work checks.
  • Verify bank account details where appropriate.
  • Conduct supplier due diligence.
  • Work with reputable recruitment agencies.
  • Review supplier practices where appropriate.
  • Investigate concerns promptly.


8. Responsibilities

Directors

The Directors have overall responsibility for ensuring this policy is implemented and reviewed.

Managers

Managers are responsible for:

  • Promoting awareness.
  • Identifying potential risks.
  • Reporting concerns.
  • Supporting investigations.

Employees

All employees are expected to:

  • Read and understand this policy.
  • Report concerns immediately.
  • Cooperate with investigations.
  • Act ethically at all times.


9. Identifying Signs of Modern Slavery

Indicators may include:

  • Individuals appearing frightened or withdrawn.
  • Someone else speaking on behalf of the worker.
  • Workers unable to produce their own identification.
  • Evidence of withheld wages.
  • Unexplained deductions.
  • Workers living at the same address under suspicious circumstances.
  • Signs of coercion or control.
  • Lack of freedom of movement.
  • Excessive working hours without proper pay.


The presence of one or more indicators does not necessarily mean modern slavery is occurring, but concerns should always be reported.


10. Reporting Concerns

Anyone who suspects modern slavery should report concerns immediately to:

Compliance Manager

or

Director

Reports will be treated confidentially wherever possible.

No individual will suffer detrimental treatment for raising a genuine concern in good faith.


11. Investigating Concerns

Where concerns are raised, Pay Hive Limited will:

  • Investigate promptly and fairly.
  • Maintain confidentiality where appropriate.
  • Work with relevant authorities where necessary.
  • Take appropriate action where concerns are substantiated.


12. Suppliers and Business Partners

We expect suppliers and business partners to:

  • Comply with the Modern Slavery Act 2015.
  • Operate ethically.
  • Treat workers fairly.
  • Prevent forced labour.
  • Cooperate with reasonable due diligence requests.

Where serious concerns arise, we may suspend or terminate business relationships.


13. Training and Awareness

We are committed to ensuring relevant staff understand:

  • What modern slavery is.
  • How to identify warning signs.
  • How to report concerns.
  • Their responsibilities under this policy.

Training will be provided where appropriate.


14. Monitoring and Review

This policy will be reviewed annually or sooner if required by:

  • Legislative changes.
  • Regulatory guidance.
  • Business changes.
  • Lessons learned from incidents.


15. Related Policies

This policy should be read alongside our:

  • Anti-Bribery and Corruption Policy
  • Whistleblowing Policy
  • Equality, Diversity and Inclusion Policy
  • Data Protection Policy
  • Recruitment Policy
  • Supplier Code of Conduct (if applicable)


16. Contact

Questions regarding this policy should be directed to:


Pay Hive Limited

Email: payroll@payhive.co.uk

Telephone: 0333 307 5511