Umbrella Company Modern Slavery Statement

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the steps that Spry Pay Limited has taken during the financial year ending 5 April 2025 to ensure that slavery and human trafficking are not taking place within our business or supply chains.

Spry Pay Limited is committed to acting ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our organisation or supply chains.

Spry Pay Limited is a UK-based umbrella company providing payroll and employment services to contractors and recruitment agencies. The company operates primarily within the United Kingdom and works with recruitment agencies, contractors and professional service providers.

Registered Office:
Spry Pay Limited
DNS House | 382 Kenton Road | Middlesex | HA3 8DP

The company is committed to operating responsibly and ensuring that all workers engaged through the business are treated fairly and in accordance with applicable employment legislation.

Spry Pay Limited’s supply chains are limited and primarily consist of professional service providers and recruitment agencies within the UK.

These may include:

• Recruitment agencies
• Accountancy and professional service providers
• IT and software providers
• Compliance and advisory service providers

Spry Pay Limited expects all suppliers and business partners to uphold the same standards of ethical conduct and compliance with laws relating to modern slavery and human trafficking.

Spry Pay Limited maintains internal policies and procedures designed to prevent modern slavery and human trafficking. These include:

• Anti-Slavery and Human Trafficking Policy
• Whistleblowing Policy
• Recruitment and Employment Policies
• Supplier Due Diligence Procedures

These policies support the company’s commitment to ensuring that modern slavery does not occur within its operations or supply chains.

Spry Pay Limited undertakes appropriate due diligence when engaging recruitment agencies, suppliers and contractors.

These measures may include:

• Verification checks of agencies and suppliers
• Ensuring contractors are paid directly into their own bank accounts
• Conducting compliance checks on recruitment partners
• Maintaining appropriate worker and supplier documentation

These procedures help minimise the risk of exploitation and ensure transparency within the company’s supply chain.

Given the nature of Spry Pay Limited’s operations, the risk of modern slavery occurring within the business is considered low. However, the company remains vigilant and maintains monitoring procedures to identify potential risks within its supply chains.

Where potential risks are identified, additional due diligence and monitoring procedures may be implemented.

Spry Pay Limited provides appropriate awareness and guidance to relevant staff to help identify potential signs of modern slavery and human trafficking.

Employees are encouraged to report any concerns regarding unethical behaviour or suspected modern slavery through the company’s internal reporting procedures.

Employees, contractors and suppliers are encouraged to raise concerns about any suspected modern slavery or human trafficking within the business or its supply chains.

All concerns will be investigated appropriately and confidentially. Individuals raising genuine concerns in good faith will be supported by the company and will not suffer any detrimental treatment as a result of reporting concerns.

This statement has been approved by the Board of Directors of Spry Pay Limited and will be reviewed annually.

Director: Wyheed Hussain
Position: Director
Company: Spry Pay Limited
Signature:
Date: 01/02/2026