Modern Slavery Statement

Modern Slavery Statement for Travel Online Group LTD trading as Currency Online Group

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and outlines the steps Currency Online Group has taken to ensure that slavery and human trafficking are not taking place in our business or supply chains.

1. Introduction

At Currency Online Group, we are committed to acting ethically and with integrity in all our business dealings and relationships. We are dedicated to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking do not occur anywhere in our own business operations or in any of our supply chains.

2. Our Business

Currency Online Group is a company that specialises in currency services. Our range of services includes Travel Cash; Currency Buyback; Automated Currency Machines; Compliance Systems; and International Payments as a broker for FCA regulated partners. 

3. Our Supply Chains

As a trusted brand in foreign exchange, Currency Online Group is committed to act ethically with integrity and transparency in all business relationships throughout the supply chain and vendor management, ensuring appropriate due diligence and ongoing assurance processes are completed to identify and assess potential risks within the supply chain and to mitigate the risks of slavery and/or human trafficking occurring. In order to deliver great service to our customers and business partners, Currency Online Group sources foreign currency from reputable, approved foreign exchange providers, ensuring appropriate validation is completed prior to sourcing, and continually reviews these customers and partners. We recognise the risks associated with modern slavery and human trafficking in supply chains. 

4. Modern Slavery Obligation

The following sets out the obligations to which Currency Online Group will continue to adhere as a socially company and describes how it will continue to ensure that steps are taken to embed into the culture of the business appropriate systems and controls in order to prevent slavery and human trafficking in the United Kingdom and across our global companies. 

From a workforce perspective, our colleagues are employed directly, and we have direct visibility of their terms of employment, training, leave entitlements and working conditions. We consider the risk of modern slavery in our direct workforce as low. 

We provide regular training to all our people to increase their awareness of modern slavery and human trafficking, so they are able to understand, identify and report on these risks. We are committed to maintaining an honest and ethical culture, ensuring our people are aware of our anti-bribery policy and zero-tolerance approach to bribery and corruption. 

5. Due Diligence Processes

To identify and mitigate modern slavery risks, we have established the following due diligence processes:

• Conducting risk assessments of our supply chains.

• Vetting and auditing key suppliers to ensure compliance with ethical standards.

• Including modern slavery clauses in supplier contracts.

6. Risk Assessment and Management

We have identified areas where the risk of modern slavery is most significant and have taken steps to mitigate these risks, including:

• Focusing on high-risk suppliers and regions.

• Engaging with suppliers to improve awareness and compliance.

7. Training and Awareness

Currency Online Group has clearly communicated to all colleagues that they must adhere to the standards outlined in the Anti-Bribery and Anti-Corruption suite of policies, which incorporates modern slavery. 

Other documents relevant to preventing modern slavery in Currency Online Group’s operations include the Global Ethical Conduct Policy along with the Vendor Management Governance Policy. Currency Online Group will continue to raise awareness of modern slavery within the colleague network, completed by training, communication, and internal dialogue. 

Currency Online Group has in place systems to encourage the reporting of concerns or breaches of policy via the whistle-blowing gateways and ensures the protection of any whistle-blower

8. Measuring Effectiveness

To ensure the effectiveness of our measures, we:

• Monitor compliance with our policies and procedures.

• Regularly review our risk assessment processes.

• Set key performance indicators (KPIs), such as the number of audits conducted and training sessions delivered.

9. Future Steps

Currency Online Group is committed to acting ethically and to comply with all laws, regulations and rules applicable to our business as well as demonstrating the highest professional standards. Accordingly, Currency Online Group will continue to monitor the effectiveness of the programme, implementing enhancements when required, and ensuring that policies and procedures in relation to modern slavery are implemented. Annual reviews will be conducted in addition to audits of the associated policies and procedures. Our approach to managing modern slavery risks is an integral part of our approach to respecting human rights and we expect our business partners to adhere to the same exacting standards and values.