At Blue Light Card (including all group companies) we take seriously our role and responsibilities in the protection of fundamental human rights, and we are committed to ensuring that modern slavery or human trafficking is not taking place within our business or supply chains.
We have a zero-tolerance approach to any form of slavery, and we are committed to acting ethically, with integrity and with transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
This policy applies to all the companies in the Blue Light Card Group, including Blue Light Card Ltd in the UK and Blue Light Card Pty Ltd in Australia, as well as their parent holding companies Project Hive BidCo Ltd, Project Hive MidCo1 Ltd, Project Hive MidCo 2 Ltd and Project Hive TopCo Ltd. Throughout this statement this group of companies are referred to as ‘Blue Light Card’.
The most senior management team or board of all of the Blue Light Card entities noted above have been engaged in the development and approval of this policy.
Blue Light Card is a market leading omnichannel consumer marketplace, providing a range of market leading offers from brand partners for its member base of first responders, emergency services, armed forces, aged and social care personnel.
We recognise the potential risk of modern slavery in three areas of our business, our colleagues/candidates, our brand partners and our supply chain. Our specific approach to assessing and mitigating the risks in each of these areas is set out in the sections below.
In all of these areas our approach is underpinned by a culture of ethical behaviour and integrity. We instil this through our company values (in particular, our core values of acting with integrity and humility) our contracts of employment and our policies. The latter includes policies relating to equal opportunities, bullying and harassment, disciplinary and grievance and whistleblowing. These policies are included in our employee handbook and made available to colleagues at all times. All polices are reviewed and updated on an annual basis.
As an organisation primarily employing professionals in lower risk countries (UK and Australia) we consider the overall risk of colleagues and candidates being in modern slavery as low. Regardless, we take a number of steps to mitigate any risk, including:
We partner with in excess of 13,000 brands. The majority of member spend with these organisations is with large, household name brands, which we deem to be at relatively lower risk of modern slavery due to their size and the reputational risk of being otherwise. Regardless, we know that many of these brand partners do not manufacture directly, and that there could still be a risk of modern slavery in their supply chain.
We are committed to increasing our understanding of this risk and have conducted an initial analysis of the brand partner industries against the SASB materiality matrix and GLAA high risk industries to identify those industries that are at greater risk of modern slavery either in their operations or supply chain and we will use this information as the foundation for developing further plans in this area.
As an online business, we have a relatively small supply chain, with the primary products and services we purchase being professional services and software. All of our significant direct purchases are from organisations based in Australia or the UK, both of which are countries assessed as being at lower risk of modern slavery in the Global Slavery Index. We therefore assess the overall risk of modern slavery within our supply chain to be low.
We monitor the effectiveness of our modern slavery approach in two ways:
Any incidents raised in either of the above ways are reviewed by the senior leadership team (escalating to the Board where required) and appropriate mitigation steps put into place.
Modern slavery training forms part of the mandatory compliance training undertaken by all colleagues upon commencement of employment and at frequent intervals thereafter.
This statement was approved and adopted by the Board on 24th January 2024 and will be reviewed and updated annually.
Name: Alidad Moghaddam, Chief Executive Officer
Date: 24th January 2024
