Modern Slavery Policy

Introduction

At Work for Impact (WFI) we are committed to maintaining high ethical standards and promoting human rights across our business operations. This policy outlines our zero tolerance stance against modern slavery and the guidelines and procedures we will follow to mitigate its presence in our business.

For the purposes of this policy “modern slavery” refers to all forms of slavery, human trafficking, forced labour, debt bondage, child labour and other similar practices. This policy aligns our company with key global standards and local Hong Kong laws to ensure that we are part of the solution.

WFI uses tools and solutions as outlined in Appendix 1 to assist the organisation manage potential exposure to modern slavery and money laundering.

WFI also applies a pro active approach via the platform, we do not allow interaction with digital agencies where WFI does not have a direct relationship with the individual or organisation.

1. Policy Statement

WFI has a zero tolerance approach to modern slavery and other illegal activity and is committed to implementing and enforcing effective risk based systems and controls to detect, prevent and mitigate the risk of exposure to modern slavery and human trafficking in its operations.

The purpose of this policy is to communicate and establish controls to ensure compliance with key anti Modern Slavery regulations, as well as ensuring alignment to WFI’s ethical standards. The policy covers all WFI directors, employees, independent contractors we engage, suppliers, customers and third-party providers and is intended to ensure all are aware of the responsibilities they hold.

Our policy on anti Money Laundering (AML) is relevant to this Modern Slavery Policy and should be read in conjunction with and as a supplement to this policy.

By adhering to this policy, WFI demonstrates its commitment to contributing to the combating of modern slavery, not merely as a legal obligation but as a core aspect of our corporate social responsibility. We at WFI are committed to acting ethically and with integrity in all areas of our business operations and relationships and to implementing and enforcing effective systems and controls to ensure that any form of Modern Slavery is not taking place in our own business.

We expect the same high standards from all other businesses we interact with.

This policy is informed by key international legislation, protocols and resources as included at Appendix 2. As noted above the policy approach and content also aligns with the WFI AML/KYC Framework and Policy.

2. Roles and Responsibilities

2.1. WFI Senior Management is responsible for setting the tone at the top and establishing a culture of compliance with Modern Slavery laws and protocols. They will allocate necessary resources, support the implementation of anti Modern Slavery measures, and ensure appropriate oversight of the program.

2.2. Compliance Officer - Work For Impact will designate an individual or team as the Compliance Officer(s) responsible for overseeing the implementation, maintenance, and effectiveness of the anti Modern Slavery program. Refer to additional information below.

2.3. All personnel and others engaged with WFI, including directors, employees, independent contractors, customers and other associated individuals, have a responsibility to comply with this policy.

2.4. Our people are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business, or businesses we interact with, at the earliest possible stage. If there is a suspicion of a breach of this policy, we request you notify the Compliance Officer as soon as possible.

The prevention, detection and reporting of modern slavery in any part of our business or network is the responsibility of all those working with us. All independent contractors regularly engaged with our
business are required to avoid any activity that might lead to, or suggest, a breach of this policy.

When considering suspicious activity, if you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any are of our business, constitutes any
of the various forms of modern slavery, please raise this with the Compliance Officer. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

3. Risk based approach

The risk based approach (RBA) is central to the effective implementation of an anti money laundering regime, in addition this approach is relevant to the management of risk associated with exposure to Modern Slavery and taking adequate steps to Know-Your-Client is a key aspect of this approach.

The level of client due diligence required depends on the risk profile of a particular client.

The relevant factors to be considered include:

background and origin of the client;
nature of the client’s business;
for corporate client, the structure of ultimate beneficial ownership and control;
purpose of the transaction to be undertaken;
source of funding; and
other information that may suggest that the client is of high money laundering and terrorist financing risk.
other information that may indicate the client may have exposure to Modern Slavery.

Our independent contractors undergo an identification check via Sumsub (refer Appendix 1) when they apply to join us. This is part of our onboarding process. The level of additional verification/vetting employed is determined by risk profile and the requirements of our customers. We also ensure independent contractor’s values align with those of WFI.

We do not engage with clients or independent contractors from high risk regions as defined by the Global Slavery Index 2023. Refer Appendix 2.

By applying a risk based approach WFI is able to ensure that measures to prevent or mitigate involvement with Modern Slavery and other illegal activity are commensurate to the identified risks. This will allow resources to be allocated in the most appropriate ways. The principle provides that resources be directed in accordance with priorities, so that the greatest risks receive the highest attention. Refer to The AML/KYC Framework pages 6 and 7 for steps to be taken with types of high risk clients.

We will regularly monitor and evaluate risk management strategies and their effectiveness.

THIS POLICY OUTLINES THE PROCEDURES AND STANDARDS:

Know Your Client (KYC)
- Customer Due Diligence (CDD)
- Verification procedures
- Sanction lists and Global Slavery Index list
Compliance Officer
Monitoring Transactions and engagement
- Ongoing monitoring
Record keeping
Communication
Training and education

4. Know Your Client (KYC)

Work For Impact establishes verification procedures within the standards of anti-money laundering and “Know Your Client” (KYC) frameworks. This framework is applicable to this policy also.

4.1. Customer Due Diligence (CDD)

One of the international standards for preventing illegal activity is Customer Due Diligence (CDD). CDD is a key part of the KYC process and requires that WFI collect and evaluate customers information and determine their risk profile for illegal transactions.

Before accepting a new client the WFI platform requires screening via Sumsub verification (KYC). This provides a desktop review to confirm legitimacy. Where digital gaps are identified, the customer is required to provide WFI with valid identification documents. In addition, our customers are subject to identification and verification processes by integration with other platforms we utilise ie Stripe. Currently only those clients who pay us directly will be subject to WFI direct verification procedures ie certain Enterprise clients. The level of evidence required is determined by the category and risk profile of the client. Additional detail on this process is outlined in our Anti- Money Laundering Policy and The associated AML Framework pages 8-10

WFI will collect and store user’s identification information for the AML/KYC and Modern Slavery Policy purposes.

4.2. Verification procedures Independent Contractors

WFI utilises tools and processes as outlined at Appendix 1 to screen independent contractors. They are also subject to verification by our payment platforms ie Stripe and Payoneer.

WFI reserves the right to seek additional verification of independent contractor identity on an on-going basis, especially when their identification information has been changed or their activity is deemed to be suspicious (unusual behaviour for the particular User).

In addition, WFI reserves the right to request up-to-date documents from its users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared and protected strictly in accordance with the WFI’s Privacy Policy and related regulations.

Refer Appendix 1 for list of resources and tools used by WFI for verification purposes.

4.3. Sanction lists, Jurisdictions of high risk, Politically Exposed Persons (PEPs) and Global Savery Index list

WFI does not open accounts or transact with individuals who are on prescribed sanctions lists. WFI screens against United Nations, European Union, UK Treasury, US Office of Foreign Assets Control (OFAC), and other sanctions lists in all jurisdictions in which WFI operates.

WFI does not serve clients from certain jurisdictions that are deemed high-risk or those under increased monitoring, according to the Financial Action Task Force FATF (April 2023), High risk - Democratic People’s Republic of Korea, Iran, Myanmar. Under increased monitoring - Albania, The Bahamas, Barbados, Botswana, Cambodia, Ghana, Iceland, Jamaica, Mauritius, Mongolia, Nicaragua, Pakistan, Panama, Syria, Uganda, Yeman, Zimbabwe.

Politically Exposed Persons (PEPs). WFI does not open accounts or transact with individuals who are Politically Exposed Persons (PEPs), or their family members. WFI screens all Clients against global PEP lists before they are allowed to establish a relationship with WFI.

WFI also does not work with people or businesses from regions considered high risk by the Global Slavery Index (GSI) 2023 for Modern Slavery as included Appendix 2.

5. Compliance Officer

The Compliance Officer is the person authorised by WFI, whose duty is to ensure the effective implementation and enforcement of the AML/KYC and Modern Slavery Policies. Currently Beth is the Compliance Officer. The Compliance Officer’s responsibilities include:

Collecting Users’ identification information where not verified when on boarded,
Monitoring and updating internal policies and procedures to identify risks,
Monitoring transactions and investigating any significant deviations from normal activity,
Implementing a records management system for appropriate storage of documents,
Development of measures to assess and address any risks of modern slavery practices, including through due diligence in our contractual relations,
Responding to issues/queries/suspicions raised,
Providing law enforcement with information as required under the applicable laws and regulations,

The Compliance Officer is entitled to interact with law enforcement officers involved in prevention of money laundering, terrorist financing and other illegal activity.

6. Monitoring Transactions and engagement

This policy does not allow for any form of Modern Slavery and we will take proactive steps to ensure that Modern Slavery is not taking place in any part of our business or business network. We will not engage with organisations likely to facilitate any form of slavery including the use of child labour or forced labour. We require that the suppliers and third parties we work with should hold their own suppliers and third parties to the same standards. We seek to continually improve awareness of the practices necessary to combat slavery and human trafficking and assess the risk profile of our business in these areas.

WFI will monitor transactions by conducting appropriate scrutiny of transactions as outlined in our AML/KYC Policy.

6.1. Ongoing monitoring

As outlined in the AML/KYC Policy WFI will conduct regular reviews of the identification documents and information in relation to our clients to ensure ongoing compliance with the relevant AML requirements. We will take the required steps to ensure documents, data and information obtained from a client are up-to-date and relevant. Refer The Framework pages 11 and 12. This process is important from the perspective of detection of involvement in modern slavery.

Ongoing monitoring of independent contractor activity will also be undertaken, ad hoc reviews of verification evidence checked and updated where appropriate.

7. Record keeping

Record-keeping is an essential part of the audit trail for the detection, investigation and confiscation of criminal or terrorist property or funds. We will ensure that appropriate records are maintained.

8. Communication

Our commitment to addressing the issue of modern slavery in our business will be communicated to all independent contractors, subcontractors, suppliers and business partners when our business relationship begins and will be reinforced as appropriate thereafter.

9. Education and training

The Compliance officer will ensure all independent contractors/contractors who are regularly engaged by WFI are provided with the Modern Slavery Policy and make recommendations to management regarding who should participate in appropriate training in areas of anti Modern Slavery education. Evidence of course completion will be required to be provided to the Compliance Officer and will be retained on WFI file.

Appendix 1 - This table outlines the tools and solutions that are in place to comply with the AML & KYC Policy plus Human Slavery Policy.

Tools	Reason	Process
Stripe Connect	KYC (identification verification)	Within the payments platform, WFI will utilise the KYC functionality for both Freelances and sellers. Both parties need to complete the full KYC-cycle and process before being able to transact on the platform.
Sumsub	KYC (identification verification)	During onboarding of independent contractors, users have to verify their identity with Sumsub- upon account creation. Sumsub is an industry leading AI-based solution, that automates identity verification and antifraud, providing bank-grade KYC, KYB, KYT compliance, AML screening and customer data storage to protect and enable regulated businesses online. Sumsub provides a 97% hit rate and with strong legal expertise Sumsub is seen among the leading players of the market. The company was founded in 2015 with its headquarters in London, United Kingdom.
Stripe Radar	Transaction Monitoring	Stripe Radar is a fraud solution that screens every transaction based on rules implemented by WFI and Machine Learning detection engines. Radar helps detect and block fraud for any type of business using machine learning that trains on data across millions of global companies. It’s built into Stripe and requires no additional setup to get started. Radar is also being used for Strong Customer Authentication (SCA) to comply with PSD2. If possible, card transactions have the need to be authorised via 3D-secure (if supported by the credit card issuer). On a daily basis, transactions reports will be analysed, monitored, checked and actioned if required.
Risk Assessment	Due Diligence on Companies	Upon boarding of new NGO’s & not for profit organisations, WFI will conduct a proper Due Diligence assessment (IDcheck, UBO’s, research via public channels, website, T&C’s, AML- checks) per company, prior to onboarding to the platform. It is noteworthy that companies who will utilise WFI are recognised companies within the industry. Nevertheless, WFI will not make any exemptions and risk assessment is mandatory.
Digital agencies	Identification/verification	WFI does not transact with digital agencies. We do not accept digital agencies via the platform and require a direct relationship with individuals and organisations transacting with us.

Appendix 2

Reference – Key legislation, protocols and resources

International Legislation and protocols

9.1. United Nations Convention against Transnational Organised Crime (UNTOC) and its Protocols

The UNTOC, adopted in 2000, is a framework treaty aimed at combating transnational organised crime. It includes three protocols that focus on specific areas, one of which is the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children (Trafficking in Persons Protocol). Hong Kong is not a sovereign state, but as a Special Administrative Region (SAR) of China, it does not sign international treaties independently. However, China is a signatory to the UNTOC and its protocols, and the obligations under these treaties extend to Hong Kong.

9.2. United Nations Universal Declaration of Human Rights (UDHR)

Committed to upholding the fundamental human rights principles as described in the UDHR, including the prohibition of slavery and forced labor.

9.3. International Labour Organisation (ILO) Conventions

The ILO has several conventions related to forced labor and modern slavery. Convention No. 29 concerning Forced Labour (1930) and Convention No. 105 concerning the Abolition of Forced Labour (1957) are particularly relevant to combatting modern slavery. Again, while Hong Kong is not a member of the ILO as an independent entity, the conventions' principles are generally applicable through China's ratification.

9.4. Global Slavery Index 5th edition May 2023(GSI)

The GSI presents national estimates of modern slavery for 160 countries, providing deep insight into the scale and composition of modern slavery today.

GSI 2023 Estimated prevalence of modern slavery by country

Country and Rank	Prevalence Rate	# of People
1. North Korea	104.6	2,696,000
2. Eritrea	90.3	320,000
3. Mauritania	32.0	149,000
4. South Arabia	21.3	740,000
5. Turkiye	15.6	1,320,000
6. Tajikistan	14.0	133,000
7. United Arab Emir	13.4	132,000
8. Russia	13.0	1,899,000
9. Afghanistan	13.0	505,000
10. Kuwait	13.0	55,000

10. Local Legislation (Hong Kong)

10.1. The Crimes Ordinance (Cap 200)

Part XIA of the Crimes Ordinance deals with human trafficking offenses. It was introduced in 2018 to enhance Hong Kong's legal framework to combat human trafficking and brings the region's laws closer to international standards

10.2. The Immigration Ordinance (Cap 115)

This ordinance includes provisions on illegal immigration and human trafficking offenses related to facilitating the illegal entry of persons into Hong Kong.

10.3. Employment Ordinance (Cap 57)

This ordinance provides protections for employees, including measures against forced labor and exploitative working conditions.

10.4. The United Nations (Anti-Terrorism Measures) Ordinance (Cap 575)

This ordinance aims to implement various UN Security Council resolutions, including those targeting terrorism and terrorist financing. While not directly related to modern slavery, it can be relevant when investigating organised crime networks involved in human trafficking.

Policy author – Beth Hoskins

Review date – November 2025

Approved – by Geoff Hucker on November 27, 2024