Last updated 14/10/2024
This statement outlines the processes e-Pocket Pty Ltd has put in place to understand and address all risks of modern slavery and human trafficking within our company. Acting in accordance with the UK Modern Slavery Act (2015) and the Australian Commonwealth Modern Slavery Act 2018, e-Pocket takes minimising the risks of modern slavery and human trafficking with the utmost seriousness, and always endeavours to implement and uphold the most effective measures to keep those risks to a minimum.
As part of the financial services industry, e-Pocket Pty Ltd understands that the only way to create a policy designed to minimise risks to modern slavery and human trafficking is with robustness, which is why we regularly review the policy, and are willing to make any necessary amendments at any time. e-Pocket Pty Ltd is committed to preventing slavery and human trafficking across all its operations, including within its internal offices, as well as when engaging with partners, contractors or any other associates. We hold all e-Pocket Pty Ltd employees and associates to the same standards regarding modern slavery and human trafficking.
As global payment facilitators, we build modern, industry-leading technology suited to both individuals and businesses. All of our clients have the opportunity to benefit from a convenient, logical process that allows them to take control of their money transfers. Our reliable system, effective processes and dedicated customer service team all combine to ensure each and every e-Pocket Pty Ltd client has complete autonomy over their finances.
e-Pocket Pty Ltd is an expanding global business, and offers its services to clients across the EU, and allows money transfers to more than 100 countries all over the world.
Since forming in 2017, e-Pocket Pty Ltd has grown substantially, from a start-up to an international company. Despite this growth, we consider the input of all our employees to be highly valuable, and as such, we empower them to contribute to the upholding and evolution of our values. We are open to ideas and suggestions, both on how we can grow our company culture, and also how we can minimise risks of modern slavery and human trafficking. With such a culture, our people are able to shape the direction of the company, which becomes increasingly important as we expand around the world. e-Pocket Pty Ltd operates under five key principles: honestly, openness, dedication, fairness and ambition. Upholding all of these values, ensures a positive company culture, and minimal risks of modern slavery and human trafficking.
Nonetheless, we refuse to be complacent. As such e-Pocket Pty Ltd, always endeavours to identify risks in our policy and operations, and make any adjustments that would ensure an even more minimal risk of modern slavery and human trafficking. We document any breaches of our code of conduct, and take any necessary action appropriate to the nature of the breach. If we consider the breach to be partly or wholly the result of lack of clarity in our processes, we improve those processes to minimise the chance of such a breach recurring. If any of the breaches are of the nature that could undermine our human rights considerations, we would address this breach appropriately.
e-Pocket Pty Ltd considers training and onboarding to be extremely important to the company. Not only do we expect all our employees to be up-to-date with our values and policies, but any adjustments to any processes are made clear to employees at the earliest possible convenience. We consider transparency to be of the utmost importance, and ensure any education employees require is conducted, to ensure everyone within the company has a universal understanding of all our expectations. Such education is considered a priority.
Whilst e-Pocket Pty Ltd currently operates in regions where there is a low risk of human trafficking and human rights violations, and whilst our sector is also in a low-risk category, we nonetheless attempt to identify all risks as effectively as possible. Anywhere that our oversight could be lesser, than say, within our offices, such as in supply chains, we gather all possible information, in order to assess any risks of modern slavery or human trafficking. If we suspect there are any risks that any agreement we have with a partner or third-party could be aiding or abetting modern slavery or human trafficking in any way, we would immediately terminate any agreement and communications, and where appropriate, contact relevant authorities. Furthermore, we conduct rigorous processes to ensure any partner or third-party we deal with acts in accordance with our values.
At e-Pocket Pty Ltd, we apply a number of policies, with the multi-faceted goals of providing the best service for the largest possible number of clients, growing and expanding the business across the globe, and maintaining the highest possible standards regarding values (in part, to ensure we minimise the risk of modern slavery and human trafficking). We write our policies with a mind to achieving conduct goals across the company, as well as business outcomes and growth goals.
e-Pocket has a range of policies that assist with the detection of modern slavery. Such policies include, but are not limited to:
Whistleblowing Policy: We hold our employees to an ‘if you see something, say something’ standard, which allows us to uphold and promote a culture of transparency and honesty. Because we understand it can be difficult for some individuals to report questionable actions or behaviours, we also ensure all employees report such incidents with zero fear of reprisal. Such incidents include, but are not limited to, suspicion of modern slavery or human trafficking.
Training: This policy ensures all employees have a full and thorough understanding of all e-Pocket Pty Ltd policies, including operations and values. Should policies be added to or amended, we ensure education is conducted at the earliest possible convenience, to ensure all employees remain up-to-date with all procedures.
Partners and third-parties: All partners and third-parties that have dealings with e-Pocket Pty Ltd provide are subject to due diligence checks, to ensure they uphold the requisite code of conduct. All third-parties, along with clients and employees, are subject to these standards, and e-Pocket Pty Ltd is confident that it ensures transparency and efficiency in our approach to preventing modern slavery and human trafficking.
Risk Assessment: As part of e-Pocket Pty Ltd’s compliance program, we continually make assessments to understand if any areas of the business are falling short of the high standards established in our policies. Should we identify that anything could lead to a potential risk of
modern slavery or human trafficking, we address and aim to mitigate this.
Code of Conduct: e-Pocket operates under a highly robust Code of Conduct. We expect all employees to act with honesty, integrity and transparency at all times. Each employee is expected to uphold the required standard individually, and to operate under the ‘if you see something, say something’ principle, to ensure the entire team is held to account.