Modern Slavery and Human Trafficking Policy
Modern slavery and human trafficking statement
This statement sets out Momenta’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2019 to 31 March 2020.
Momenta recognises that it has a responsibility to take a robust approach to slavery and human trafficking and are absolutely committed to preventing slavery and human trafficking in its corporate activities and ensuring that its supply chains are free from slavery and human trafficking.
Organisation structure and supply chains
This is a single statement to cover the activities of all companies within the Momenta Group, comprising of the following entities:
- Momenta Acquisitions Limited
- Momenta Associates Pty Limited
- Momenta Customer Services Limited
- Momenta Group Holdings Limited
- Momenta Holdings (PPI) Limited
- Momenta Resourcing India Private Limited
- Momenta Interim Management Limited
- Momenta Operations Limited
- Momenta People Limited
- Momenta Performance Academy Limited
- Momenta Resourcing Asia Limited
- Momenta Resourcing Deutschland GmbH
- Momenta Resourcing Inc.
- Momenta Resourcing Pty Ltd
- Momenta Solutions Limited
Momenta is a supplier of flexible, contingent resource primarily serving the financial services industry. Our head office is in London with further offices in; Australia, Hong Kong, India, Germany and USA.
Our supply chain requirements are predominantly related to the deployment of people to our clients. We understand this is our biggest potential area of exposure.
During the last year we have developed our supply chain to introduce new territories.
Our supply chain usually runs as illustrated here
Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
Policies in relation to slavery and human trafficking
Our relevant policies, which are available to all staff include:
- Corporate Social Responsibility Policy
- Equal Opportunities Policy
- Global Recruitment Policy
- Whistleblowing Policy
Due diligence processes
We will not support or deal with any businesses knowingly involved in slavery or human trafficking.
When onboarding a new client or Umbrella Company we carry out a number of preliminary checks: web domain, company number, VAT number, credit check, company accounts have been filed and incorporation check.
Our contractors are engaged as suppliers through a Contract for Services. Where that engagement is through an ‘umbrella’ company, a thorough process of due diligence is completed to ensure adherence to a range of standards including the company’s policy and practices in relation to The Modern Slavery Act.
To minimize risk from April 2020 we have selected two preferred Umbrella Companies, Trafalgar Contractor Solutions Limited and PayStream Accounting Services Ltd. Due diligence undertaken on the Umbrella Companies included checking: who is in control of the company, the size of the firm (turnover, number of clients and staff), what standards they work to (eg ISO) and how they are audited.
We adhere to the national minimum wage (NMW)/national living wage (NLW).
Risk assessment and management
To minimize risk, all contractors and employees undergo a thorough background screening process which verifies their identity and eligibility to work status. Momenta has seen growth as a business into new global territories and have extended our screening checks into these areas.
Momenta employees working in our vetting teams receive stringent training on how to screen potential employees and contractors. Checks on contractors and employees include: Passport checks to confirm image and validity of passport, eligibility to work in the UK, proof of address in the UK and references.
As part of our global expansion we have established a new territory in India. We recognise this exposes us to increased risks and are reviewing our processes, procedures and training accordingly.
As a company we have signed up to receive updates and guidance from the Home Office Modern Slavery Unit.
Key performance indicators to measure effectiveness of steps being taken
Our competency framework also sets out the behaviours we expect from employees in their dealings with colleagues, clients, suppliers and contractors. These competencies are reinforced through the performance management process and reward strategy.
Momenta in the UK requires all employees to complete training on modern slavery. The training covers how to identify the signs of slavery and human trafficking; what initial steps should be taken if slavery or human trafficking is suspected; how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation and what external help is available. We are now extending this training into our new global territories.
We will continue to keep awareness high amongst employees to ensure they know how they can identify and prevent slavery and human trafficking, they know what to do to flag any potential issues and where to go for help.
This statement was approved on 29th March 2020 by Momenta’s board of directors who review and update it annually. Momenta is committed to an ongoing review of its policies, practices, mapping of supply chain and training programme. Current actions are; reviewing our onboarding process for new clients, developing and mapping our supply chains in new territories, reviewing the frequency of training and rolling out training in our new territories.
Chief Operating Officer