Stream Anti-Slavery and Human Trafficking Statement

Policy Information & Governance

Background

Stream Holdings Ltd “Stream” was founded to be a strong force for social good, providing a complete financial wellbeing platform for frontline workers. This is embedded in the ethos of our company - a social charter designed in conjunction with our charity investors. As a result, our Articles of Association are unique, stating:

“Subject always to the Directors’ fiduciary duties, including those under section 172 of the Act, the Company’s objective is to secure a return to its Shareholders, and, for the public benefit, create technology solutions that reduce the poverty premium and help workers improve their financial wellbeing”.

Stream is strongly committed to ensuring that our organisation is free from slavery and human trafficking, and that all Stream staff, and affiliates, are protected. We envisage a world where all people and communities thrive due to economic stability and social equality - this is the core principle behind our business and purpose.

Purpose

As a financial wellbeing company, our business model does not carry with it a high level of slavery risk. This policy therefore covers those areas within our business supply chains which we have identified as presenting a potential slavery risk.

Scope

This policy applies to all Group employees, contractors, partners, clients and suppliers.

Governance

This policy is owned by the General Counsel and is approved by the Group Risk Committee. The policy is to be reviewed annually.

Exceptions, Waivers & Breaches

The Group does not anticipate granting any exceptions or waivers to this policy.

Policy breaches will be escalated to the GRC team immediately. When it is determined that a breach of this policy has occurred, Stream may take such action as deemed appropriate, such as, invoking the disciplinary procedure or, in the case of clients, suppliers and partners, invoking contractual clauses which allow contracts to be terminated with immediate effect.

Training

All employees and contractors will read and acknowledge this policy within 30 days of joining Stream and on an annual basis thereafter.

Policy

Policy Statements

• Stream operates a rigorous recruitment selection process for all employees, including obtaining proof of Right to Work documents in the country in which they will be employed.
• Stream will always pay employees at least the minimum wage rate applicable in the geography in which they operate (and are committed to paying the London Living Wage for employees based in London)
• Our Company Values, Policies and Code of Conduct provide a clear set of rules for all employees and contractors and the standards expected across all areas of our business including in relation to modern slavery concerns.
• Stream is committed to act with integrity in all of our business activities and to comply with all applicable laws and regulations where we do business
• Stream does not tolerate slavery or human trafficking within our supply chains

Additional Policy Rules & Information

Employee Background Checks

Stream completes background checks on all new employees as part of their recruitment and onboarding process. Stream will not hire employees or contractors where a background check has returned flags related to slavery or human trafficking.

Supplier Due Diligence

Stream undertakes due diligence on potential suppliers to ensure that they are a suitable organisation aligning with Stream’s values and policies.

In line with our supplier due diligence and assurance frameworks, we monitor suppliers on an ongoing basis to ensure they remain aligned to our values and policies. Stream is committed to ensuring that there is no slavery or human trafficking arising in any part of our business, including our supply chains.

All suppliers are required to adhere to our supplier code of conduct which sets out clearly our expectations and the standards of behaviour we expect from all our suppliers.

Oversight, Reporting & Management Information

Oversight and reporting for this policy will be included in the ongoing risk management assessment and reporting of Supplier and People risks which is reviewed by entity level risk committees.

Escalation & Issue Management

Any issues of Group level significance arising as within an entity will be escalated from the entity risk committee to the Group Risk Committee.

Roles and Responsibilities

Risk Owners

• Identify and assess risks related to slavery and human trafficking as part of ongoing risk management

Supplier Relationship Owners

• Report suspected or confirmed supply chain issues linked to slavery and/or human trafficking.

People Team

• Complete employee and contractor background checks as part of recruitment and onboarding process.
• Complete ongoing background checks at least annually for all employees and contractors.

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