Modern Slavery Act and Transparency in Supply Chains
Statement – for financial year ending June 2023
Modern slavery is a serious and heinous crime which violates human rights, destroys communities and causes significant harm to victims. At Ordo we actively endorse and support objectives to eradicate slavery, servitude, forced or compulsory labour and human trafficking, and make choosing partners who pay their workers fairly, compulsory. Ordo is committed to high ethical standards in all aspects of running our platform and business.
We are committed to actively guarding against modern slavery and related crimes and unethical behaviour arising in our business and supply chain.
About Ordo
We have built and operate a highly secure, cloud based, open banking enabled payments platform which provides businesses large and small with low cost, secure and easy to use e-commerce, Point of Sale and invoice payments direct from their customer’s bank accounts into their own bank accounts.
Our platform handles all the complexity of setting up, initiating, and tracking open banking payments for over 98% of UK consumer and small business bank accounts.
We manage not only the specialised open banking and instant payments flows, but the business process requirements of businesses and every step of the interaction with their end customers, providing customisable payment journeys for each business client.
Businesses can access the Ordo platform in a number of ways: though an Ordo Merchant Acquirer/PSP payments partner, via Ordo’s modern APIs, and for smaller businesses, through our integrations with QuickBooks, Sage, and Xero accounting software or directly via Ordo’s web/app interfaces.
Ordo also uses open banking payments to deliver refunds and secure customer pay outs as well as enhanced account validation services.
About this statement
This statement is issued by the board of The Smart Request Company Limited, trading as Ordo (“Ordo”). We are FinTech which has been established since 2018. At our core, we are a group of specialist experts, a dedicated team with the benefit of all of the senior management team and board being able to retain a close eye on operations and supply management.
In order to provide our platform at scale, we outsource the operation of our platform to benefit from robust scale and secure systems, with our platform run by CGI IT UK Limited (”CGI”).
As a financial services platform orchestrator and provider, all of our own employees, and the vast majority of the employees that are involved in the provision of our service at CGI, are highly skilled and specifically retained for particularly sought after skill sets; we therefore consider the risk of modern slavery and forced labour within our own work force and that of CGI to be low. Employees who have concerns about their working conditions are encouraged to speak with their line managers, and, if their concerns are not resolved, they may raise the matter with any founder director of the company who are widely and frequently in attendance at all levels of meeting and available on a one to one basis. However, forced labour exists in many different sectors across the world, and we recognise a robust approach is required both internally for our own organisation, and CGI with whom we work extremely closely, and the few other suppliers that we retain, who are largely all long term suppliers who act as our close partners.
This statement reflects our established commitment to providing safe and fair working conditions for all our employees. It also reflects the way in which we choose and work with our partners and suppliers to ensure socially responsible and ethical business practices are embedded throughout our organisation and beyond, and ensure these values and assurances are written into our contracts.
Combatting slavery and human trafficking – our risks
Ordo recognises that slavery is both illegal and unacceptable.
The risk of modern slavery within Ordo’s own organisation is low. We have few suppliers, and the services we offer and use suppliers to complement our offering are for technology and business expertise. We do not have lower paid jobs and do not generally need contractors to supply lower wage tasks which are particularly vulnerable to this kind of exploitation.
Managing risks in our Supply Chain
Whilst we do not have many suppliers nor have a need for services that are unskilled, those we do have we review very closely. They are predominantly smaller suppliers, technology experts, who have uncomplicated supply chains themselves, if any, and have oversight over the full chain.
With regard to our most material supplier, CGI, we have required them to contractually, and from a policy and company culture point of view, commit at senior level to anti-slavery practices and monitoring. Where our suppliers have anti-slavery policies themselves, we review their oversight, due diligence and conduct and discuss this with them to ensure sincerity and that due importance is given to this issue.
Recognising our highest exposure to modern slavery is through our supply chain, we take a personal, robust and thorough approach to ethical and sustainable procurement. As a socially responsible organisation, we ensure our suppliers meet high standards regarding human rights, the environment and employment issues.
Living Wage commitment
Ordo pays all its employees above the certified Living Wage. The real Living Wage is an independent calculation according to the actual costs of living. It provides a voluntary benchmark for employers wanting to ensure their staff earn a wage they can live on, not just the government minimum. In addition to Ordo’s employees being above Living Wage rates, we require our suppliers to commit paying Living Wage or Living Wage equivalent (where staff are overseas) rates to staff involved in contributing to the provision of Ordo; this largely applies to our material supplier, CGI, from whom we have a contractual commitment to this effect.
Recruitment and training
Ordo is committed to high standards of human rights and this is reflected throughout our recruitment practices and on boarding process. When joining Ordo, our employees are never required to pay recruitment or agency fees and we do not confiscate identification as part of becoming an employee. And, as part of our commitment to ensuring a slavery-free workforce, our employment contracts include the following provisions:
- Freedom of members to terminate their employment with us at any time
- Freedom of movement to live and work from anywhere providing they are able to commute to Central London from time to time when needed
- Protection from any threat of violence, harassment and intimidation in the workplace
- Freedom to work for own wages and not in bonded labour
- Obligation to work is not used as a disciplinary measure
- Overtime is not compulsory, and staff are regularly reminded to take all their annual leave, and to contact their line manager should they be struggling
Outside of direct applications or referrals from colleagues and direct applications from LinkedIn, we only use reputable employment agencies on whom we have conducted due diligence and speak to personally before engaging to source new employees.
Reporting and remedy
If a specific case of modern slavery is identified or suspected in the UK, the directors and founders of Ordo would deal with the matter immediately and personally, engaging the appropriate authorities such as the police immediately on 101 or via the Modern Slavery Helpline by phone at 08000 121 700 or online at https://www.modernslaveryhelpline.org/report. Where any potential victims are in immediate danger we advise 999 emergency be called.
Board review
The senior management of Ordo are fully supportive of taking steps to ensure that no modern slavery or trafficking occurs in our operations or those of its suppliers. In the UK, Ordo has appointed Fliss Berridge, Co-founder, General Counsel and Director, to lead Ordo’s response to modern slavery. Fliss reports any suspected or actual cases of slavery to the Ordo board of directors.