Modern Slavery Statement Issued pursuant to Section 54 of the UK Modern Slavery Act 2015 This statement sets out the steps that Stonebridge Payment Solutions Ltd has taken during the financial year 2025/2026 to prevent modern slavery and human trafficking within our business operations and supply chain. Stonebridge maintains a zero-tolerance approach to all forms of modern slavery, including forced labour, servitude, bonded labour, child labour and human trafficking. We are committed to acting ethically, transparently and with integrity in all areas of our business. 1. Our Organisation Stonebridge is a specialist contracting subcontractor that operates across the UK, with significant activity in the construction, contracting and labour supply sectors. We work with: Individual workers Recruitment agencies End clients and contracting organisations Because the temporary labour sector presents known risks, we apply robust compliance and due-diligence systems to ensure ethical labour practices throughout our operations, and retain the services of leading tax and employment law specialists to ensure our continuing compliance with relevant legislation. 2. Our Supply Chain Our supply chain includes: Workers engaged via our umbrella employment model Recruitment and contractor agencies Limited companies / PSC contractors / Self-employed contractors Professional service providers (legal, payroll, training, insurance, banking) We recognise that labour supply chains can be complex, and risks of exploitation may arise where multiple intermediaries are involved. We work to understand and monitor these risks at every stage. 3. Our Policies We maintain the following internal policies which support our stance on preventing modern slavery: Modern Slavery & Human Trafficking Policy Right to Work and Identification Policy Whistleblowing Policy (Anonymous Reporting Available) Supplier & Agency Code of Conduct Anti-Bribery & Corruption Policy These policies outline reporting channels, behavioural expectations, and our commitment to transparency and protection for whistleblowers. 4. Due Diligence Procedures We undertake extensive checks on all workers, agencies, and supply-chain partners before entering into any contractual relationship: Workers Full Right to Work checks, including digital identity verification in line with Home Office standards. Verification that all workers are paid into their own bank accounts, unless a justified exception is supported with full written consent from both parties. Bank account checks for PSCs to ensure payments go to business accounts only. Monitoring of unusual working patterns, third-party control, debt indicators or signs of coercion. Agencies & Clients Verification of agency legitimacy and compliance with employment and tax legislation. Checks on ownership, trading history, Companies House records and payment practices. Requirement for agencies to adhere to our Supplier Code of Conduct. Audit rights to review labour practices where risk is identified. 5. Risk Assessment & Management We regularly review modern-slavery risks within our business and supply chain. Current areas of higher risk include: Migrant workers in the construction and labour supply sectors Workers introduced through long supply chains Use of third-party labour providers To mitigate these risks, we: Conduct enhanced due diligence on high-risk roles, industries, or territories Flag and review irregular payment instructions or third-party involvement Require annual re-verification of partner agencies Use automated systems to detect unusual activity (duplicate correspondence addresses, shared contact numbers etc.) 6. Training & Awareness All internal staff receive regular training on: Recognising indicators of modern slavery Conducting compliant Right to Work checks Responding to concerns and escalating safeguarding issues Their responsibilities under the Modern Slavery Act Front-line compliance and onboarding staff receive enhanced training. 7. Measuring Effectiveness (KPIs) To assess the effectiveness of our approach, we monitor: Number of staff trained and retrained each year Number of audits conducted on recruitment agencies Right to Work compliance rate Number of suspected exploitation cases flagged and resolved Time taken to address reported concerns Review of variations or anomalies in payment instructions We use this data to continually improve our systems and processes. 8. Reporting Concerns Concerns regarding possible modern slavery can be reported via: Our internal safeguarding team Anonymous whistleblowing channels External agencies such as the Modern Slavery Helpline All reports are treated confidentially, and we protect anyone who raises concerns in good faith. 9. Commitment to Continuous Improvement We are committed to strengthening our controls each year. During 2025/2026 we will: Introduce enhanced supply-chain mapping across agency partners Increase frequency of internal audits Embed improved digital monitoring tools to identify exploitation indicators Review and update our Supplier Code of Conduct Approval of this Statement This statement has been approved by the Board of Directors of Stonebridge and is signed by the Chief Executive Officer. This policy is reviewed annually or earlier if legislation changes. Name: David O’SullivanPosition: Chief Executive OfficerApproval Date: 25/11/2025Signature: David O’SullivanPublished: 25/11/2025 Our accreditations Speak to an expert Our dedicated team are on hand and ready to offer all the help and guidance you need Request a Callback Refer A Contractor Are you already working with us?
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