Modern Slavery Act Statement

DivideBuys Modern Slavery and Human Trafficking Statement 2020-2021

 

Introduction

This statement is made in accordance with the Modern Slavery Act 2015. It outlines the steps that DivideBuy has taken and will continue to take to ensure neither modern slavery nor human trafficking is practiced within the business or by its suppliers.

This statement applies to all DivideBuy and all associated entities where applicable.

The statement has been produced in accordance with The UK Modern Slavery Act 2015 (“MSA”), which came into force on 29 October 2015, and outlines the steps DivideBuy has taken to identify and address the risks of modern slavery to its supply chain and business operations.

About DivideBuy

DivideBuy is a consumer retailer credit provider, founded in 2014, offering interest free finance in a simpler, easier way for retailers and consumers. We work in partnership to offer retail POS credit solutions to over 500 retailers. Our eCommerce credit plugin integrates seamlessly with shopping cart functionalities such as Shopify, Magento, WooCommerce and Craft Commerce. We are striving to become the most utilised point of sale credit payment technology.

DivideBuy are regulated by the Financial Conduct Authority (FCA)

Our commitment to the Modern Slavery Act 2015

DivideBuy is committed to the principles and provisions of the Modern Slavery Act 2015, and the eradication of modern slavery. DivideBuy always conducts its business in compliance with all legislation and regulation, which are relevant to our business within the United Kingdom.

DivideBuy have internal policies, instructions, and governance demonstrating our commitment, requiring employees to raise concerns in relation to any identified or suspected non-compliance, and confirming that employees will not suffer any detriment for raising such concerns.

Related Policies

DivideBuy has a series of existing policies that collectively, and supported by underlying systems and processes, contribute towards the mitigation of the modern slavery risks that DivideBuy may face.

Anti-Bribery and Corruption Policy

Bribery and corruption, especially in supply chains, are risks that have contributed to the spread of modern slavery around the world. Without corrupt activity, including the acceptance of bribes, many of the conditions that lead or influence the extent of modern slavery may not exist.

Whistleblower Policy

DivideBuy’s Whistleblower policy encourages ethical conduct by providing mechanisms for any former or existing employee, or party associated with DivideBuy’s supply chain, to speak up and report actual or suspected wrongdoing. This policy is a vital element in establishing and supporting one of our core values of ‘Do The Right Thing.’ Unless individuals feel they can safely, and without consequence, report inappropriate conduct, that conduct would likely persist.

AML/CTF Program

DivideBuy understands that the prevention of money laundering and terrorism financing is a vital component of our efforts to mitigate modern slavery risks in our business. Money laundering in particular is closely related to modern slavery, as this activity can help to obfuscate funds that were generated through illegal activities such as human trafficking.

Employee Code of Conduct

DivideBuy’s Employee Code of Conduct helps to ensure that all DivideBuy employees not only act in accordance with all relevant laws, but also with openness, honesty, fairness, and integrity. The Employee Code of Conduct underpins all of DivideBuy’s business operations and promotes ethical business practices that mitigate the risk that any of DivideBuy’s business operations contribute to modern slavery and any other human rights abuses.

Our Supply Chains

In acknowledging the aims and abiding by the provisions of the Modern Slavery Act 2015, DivideBuy continuously maintain effective systems and controls to ensure that our supply chains are transparent and free from modern slavery.

We commenced work to enhance several internal processes to mature and centralise elements that will improve our controls and oversight of our supply chain and business operations.

New Supplier Onboarding Checks All new suppliers are subject to a risk assessment process to determine if they have factors that increase their modern slavery risk.

Most of our financial products and services are technology related with the assistance of suppliers throughout the UK and specific international regions and with DivideBuy’s highly skilled employees. As a result of using primarily a local workforce, DivideBuy faces minimal risk of modern slavery. DivideBuy selects suppliers which hold the same high business standards and core values as it does.

Key internal policies, manuals and processes include but are not limited to:

– Outsourcing

– Authorisation

– Due Diligence

We follow a due diligence process to review not just new but existing supply chains, to identify any modern slavery risk areas which require risk management action. We also conduct ongoing monitoring of out supply chain, to highlight modifications that can be made to identify and prevent modern slavery issues from arising in our supply chains.

Reducing the risk of modern slavery is of high importance to DivideBuy. We are striving to continuously improve process and approaches for this.

One part of risk mitigation is surveying the supply chain, where the manufacturing of ‘merchandise’ has been identified as having a higher-than-average risk of modern slaver

Supplier Code of Conduct

DivideBuy expects suppliers to influence their own supply chain to adopt a safe, fair, and ethical approach to their operations and to demonstrate adherence with the Code of Conduct. The Code does this through placing the obligation on suppliers to monitor their compliance, notify any breaches and take reasonable steps to address, resolve and prevent further breaches of the Code. We are currently in the process of incorporating the Code into all future supplier contracts.

Training

We are committed to providing training on the importance of the Modern Slavery Act 2015, and ensuring modern slavery is not practiced within the business or by its suppliers.

All staff will undertake training which includes e-learning sessions facilitated by compliance, on employee’s responsibilities in recognising modern slavery; additionally, courses for new leads, and new training on anti-money laundering & counter terrorist finance was rolled out in 2020.

Duty to report

It is the responsibility of all those working for or on behalf of DivideBuy, or under our control, to detect, report and prevent modern slavery from occurring within our business or supply chains. If there are any concerns or suspicions that modern slavery may be present in any part of our business or supply chains, all are encouraged to report it at the earliest possible stage to the compliance function.

To Whom does this apply

The applies to all persons working for or on behalf of DivideBuy in any capacity, including all employees, partners, interns, agents, contractors, external consultants, third-party representatives, and business partners, regardless of where they are operating. Any reported non-compliance with the Modern Slavery Act 2015, internal policies, instructions, manuals, processes, and governance will be investigated and may lead to disciplinary action and dismissal (employees) and immediate termination of contract (suppliers and contractors/consultants).

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