Umbrella Company Modern Slavery Statement

Modern Slavery Act

We know that slavery, servitude, forced labour and human trafficking (“modern slavery”) is a global and growing issue, existing in every region of the world and in every type of economy.

Spry pay Ltd has a zero-tolerance approach to modern slavery of any kind within our operations and supply chain (our supply chain being anyone that provides a product or service to us). Spry pay employees are required to report any concerns through our internal reporting channels.

Policies and control

We have zero tolerance for any form of modern slavery anywhere in our business and supply chain. Spry pay will act upon and take seriously any allegations that there may be violations relating to modern slavery. All reports will be fully investigated, and appropriate remedial actions will be taken. Spry pay has the following policies in place which demonstrates Spry pay’s commitment to tackling and abolishing modern slavery within its supply chain and which enables reports to be made and action to be taken:

  • Equal opportunities policy
  • Anti‐bribery and corruption policy
  • Anti‐slavery and human trafficking policy
  • Grievance policy and procedure
  • Whistleblowing policy

Why Spry Pay for your Preferred Supplier Lists (PSL)?

Established in 2005, we are an award-winning firm with in-depth knowledge of the contracting industry, keeping you and your contractor’s safe.

At Spry Pay, we take compliance seriously and have robust processes in place to ensure we are fully compliant.

Due Diligence Process For Modern Slavery

As part of our initiative to identify and mitigate risk we have taken various steps to ensure our business has systems in place to:

  • Identify and assess potential risk areas in our supply chain
  • Mitigate the risk of slavery and human trafficking occurring in our supply chain
  • Monitor potential risk areas in our supply chain
  • Protect whistle‐blowers

This is being achieved by:

  • The introduction and implementation of our anti‐slavery and human trafficking policy
  • which reflects our commitment to acting ethically and with integrity in all our business relationships
  • Putting in place a reporting channel which all group employees are aware of
  • Committing at director and management level to take immediate action regarding any workplace concerns raised through our reporting procedures
  • Conducting appropriate audits/risk assessments relating to the potential risks within our supply chain
  • Stringent anti‐money laundering checks
  • Compliant right to work and identity checks
  • Ensuring that all employees are paid at least the national minimum wage or national living wage.

Our commitment to compliance

To ensure that Spry pay and our supply chain comply with our ethics, values and policies we have a dedicated team responsible for making sure that all aspects of Spry pay’s business are compliant with this statement and our anti‐slavery and human trafficking policy. The compliance team consists of directors or senior management from the following departments:

  • Employment business
  • Human resources
  • Compliance
  • Facilities and procurement

Spry pay also has in place a programme that consists of:


  • Ensuring that our systems hold all relevant employee information and are completely auditable
  • Stringent anti‐money laundering, right to work and identity checks
  • Quarterly risk assessments to measure how effective we have been to ensure that slavery does not exist in our business and supply chain


  • Reviewing and implementing new agreement and contracts with suppliers to ensure they are also committed to the abolishment of slavery and trafficking by ensuring compliance in their own business and subsequent supply chain


  • Providing training to our employees to ensure a high level of understanding of the risks of modern slavery
  • Offering education awareness to direct suppliers
  • Signposting to confidential support

Spry pay will continue to monitor and measure the effectiveness of our compliance program by:

  • Reviewing annually the number of reports/concerns raised through our internal channels from employees
  • Reviewing all grievances raised internally and externally which may allude to modern slavery
  • Reviewing annually the number of issues identified when conducting supply chain risk assessments
  • Each year we will report on the effectiveness of the measures taken and the outcome of the reviews undertaken above to include:
  • Employee training levels
  • Actions taken to strengthen the supply chain auditing and verification process
  • Investigations undertaken into any reports received about modern slavery and what remedial actions were taken in response

This statement is made pursuant to section 54(1) of the modern slavery act 2015 and constitutes Spry pay Ltd slavery and human trafficking statement.