Modern Slavery and Human Trafficking Statement for the Financial Year 2019
epyx Limited understands the importance of conducting our business ethically and we place the same expectations on our supply chain.
This statement is made on behalf of epyx Limited, pursuant to section 54 of the Modern Slavery Act 2015 (“Act”) and sets out the steps we are taking to eliminate modern slavery from within our operations and supply chain.
We seek to reassure our customers, partners, investors and employees that modern slavery, including forced labour and human trafficking, has not unknowingly found its way into our supply chains. This statement is reviewed and, where necessary, updated prior to each new financial year demonstrating epyx Limited’s continuing commitment to our obligations under the Act.
epyx Limited is one of five UK based affiliated businesses owned by FLEETCOR UK Acquisition Limited which operates as a subsidiary of FLEETCOR Technologies, Inc.
epyx Limited operates out of its offices based in Meriden – Heath Farm, Hampton Lane, Coventry CV7 7LL and has approximately 130 staff members.
Our approach to Modern Slavery and Human Trafficking
epyx Limited is committed to adhering to and complying with the Act and does not knowingly employ or condone the use of forced labour, including child labour or bonded labour.
Recruiting of new employees includes identity, right to work and residency status checks to ensure potential employees are identified effectively and appropriately using official forms of identification. These background checks form the basis of epyx Limited being able to make an offer of employment to individuals who are successful during the interview process. epyx Limited recruits for full-time, part-time, temporary and fixed term positions.
Temporary workers are utilised within the business during periods of increased workload. However, all employees are on-boarded into the business using the same defined policy and process as permanent employees and contractors.
Currently, epyx Limited does not provide standalone modern slavery training or related materials to its employees. Having said that, epyx Limited has adopted a number of supporting policy documents that highlight the company’s approach and expected standards.
The current policies include but are not limited to:
- FLEETCOR UK Responsibility and Sustainability Policy
- FLEETCOR Code of Business Conduct and Ethics
- FLEETCOR UK and Europe Whistleblowing Policy
Training , including in relation to the relevant policies, is provided to all staff as part of the on boarding process and then refreshed annually, which includes a formal assessment to demonstrate understanding. Training completion rates are monitored and reported upon by the Compliance Department throughout the year.
Through our whistleblowing policy staff have the opportunity to report any unethical or illegal behaviours, such as modern slavery, through anonymous reporting to the Head of Compliance. Our Head of Compliance will independently investigate any report submitted. We have had no concerns raised by our employees regarding modern slavery throughout 2018.
The nature of our business is such that our supply chains are short and all of our products or raw materials are procured from reputable suppliers. We do not procure goods or services from higher-risk countries.
epyx Limited has taken the opportunity, presented through the creation of this statement, to review existing wording inserted into supplier contracts. epyx Limited continues to review its high-risk supplier contracts and where appropriate and deemed necessary, contractual provisions continue to be updated.
Risk Management/ Risk assessment
The nature of our business and our supply chain (provision of services rather than manufacturing products) is a relatively simple model, which allows us to assess the risk of potential modern slavery offences taking place as low. However, epyx Limited remains committed to ensuring modern slavery does not find a way into any existing, or future, supply chain relationships. The epyx Limited business is supported by a dedicated Legal Department who work closely with the Compliance Department and are responsible for agreeing acceptable contractual wording and the insertion of our expectations and standards into written agreements where the potential for modern slavery risk is identified.
Key Performance Indicators (KPls)
epyx Limited does not currently consider its suppliers to be vulnerable to pressures around service level agreements, pricing and cost reduction. However, we remain mindful of how these areas, amongst others, can leave a business vulnerable to the risks of modern slavery, and we continue to monitor the impact of service level agreements on our suppliers. Whilst not identifying the need for KPls to monitor performance we are to committed to regularly monitoring and reviewing our supply chain to ensure our assessment remains valid.
Modern slavery, human trafficking and forced labour continue to be one of the great human rights issues of our time. With thousands of victims of this despicable crime throughout the UK alone, it is critical that businesses act responsibly and work collaboratively to support the aspiration of eradicating this criminal activity from our society. epyx Limited remains committed to evidencing its ongoing compliance with its obligations in relation to modern slavery and will continue to monitor practices and policies to identify areas where improvements should be made.