This statement is made on behalf of New Wave Capital Limited (registered number 07959823) and its subsidiaries pursuant to section 54(1) of the Modern Slavery Act 2015 (the "Act") and constitutes our slavery and human trafficking statement.
The statement
New Wave Capital acknowledges modern slavery and human trafficking as an abuse of human rights and is committed to upholding the highest ethical standards and complying with all applicable laws.
New Wave Capital's business provides business accounts to Small to Medium Enterprises (SMEs) with access to a revolving credit limit. As a firm with relatively simple supply chains including administrative, financial, technology and customer support, we have concluded that there is a limited risk exposure of slavery or human trafficking taking place. Material suppliers are subject to an appropriate level of due diligence on their appointment and on an ongoing basis.
In 2022 we committed to implementing further controls to help guard against modern slavery risk. In line with this New Wave Capital completed a formal supply chain risk assessment against all our vendors/suppliers, which concluded that our exposure to modern slavery and human trafficking is limited.
We recognise the government guidance “Transparency in Supply Chains: A practical guide” and the “Global Slavery Index” to be a good practice, therefore seek to continually improve and implement effective systems and contro;s to ensure modern slavery is not taking place anywhere within our business or supply chain.
Suppliers/Vendors/Partners
New Wave Capital has a robust vendor due diligence process that enables us to detect any potential human abuse violations from suppliers/vendors/partners. New Wave Capital has a zero-tolerance approach for engaging vendors that actively engage with human rights violations and abuses, including modern slavery and human trafficking.
During the financial period to 31 March 2023 we have continued to complete due diligence reviews of our new and existing suppliers which includes assessing modern slavery risk and obtaining evidence of compliance where appropriate. New Wave Capital is not aware of any of its suppliers which do not comply with the Act and no breaches have been reported by New Wave Capital staff or partners during the period. We have additionally continued to ensure that our organisational policies are followed by all partners of New Wave Capital.
As New Wave Capital does not have intricate or complex supply chains, no further action with regards to slavery and human trafficking has been deemed necessary at this time.
Employees
New Wave Capital is committed to ensuring that we maintain high standards with our own employees (PAYE employees, contractors, or any other personnel paid to act on our behalf). We maintain a suite of internal policies that ensure all colleagues are employed, paid and treated fairly. All employees have the necessary documentation to legally work in the UK and no-one under the legal minimum age for admission to work is or will be employed.
Third party agencies that we engage for recruitment purposes are also subject to our vendor due diligence processes to ensure our partners meet our ethical standards.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes New Wave Capital’s slavery and human trafficking statement for the financial year 31 March 2023 as approved by the Board of Directors.
Signed off by the Risk Committee, April 2023