Tide's Modern Slavery Act Statement 2024
This statement outlines the measures we have taken to identify and address potential risks of modern slavery in our business operations and supply chains during the financial year 2024. This is Tide's fourth Statement on Modern Slavery and Human Tracking, published in accordance with the Modern Slavery Act 2015, and includes our subsidiary Tide Platform Ltd.
Tide is guided by the International Bill of Rights and supports the United Nations Universal Declaration of Human Rights and the fundamental rights set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, including freedom of association, the elimination of forced labour and child labour, and the elimination of discrimination in employment.
We are committed to establishing and enhancing our systems and controls to prevent modern slavery and human tracking, as well as working to increase our employees’ awareness of these critical issues. We also collaborate with regulators and law enforcement to identify modern slavery and human tracking in order to combat it in the communities and environments where we operate.
As perpetrators of modern slavery may generate proceeds of crime, which could constitute money laundering oences and be a source of terrorist financing, we recognise that public authorities may impose sanctions for human rights abuses, including modern slavery. Additionally, we acknowledge that bribery and corruption can contribute to such abuses.
In terms of Compliance with Section 54 of the Act, which requires that organisations of Tide’s size publish a Modern Slavery Statement. We have been doing this since June 2022, and in that time period we have not received any reports from employees, the public, or law enforcement agencies indicating that modern slavery practices are taking place in our supply chain.
About Tide
Tide’s mission is to save time and money for people who work for themselves, so that they can get back to doing what they love, running their businesses.
By championing small and medium-sized businesses—the lifeblood of the economy—we’re committed to helping them thrive and grow. Tide serves over 700,000 members in the UK, over 700,000 in India and has more than 2,500 employees (who we call Tideans) across our locations in the UK, in India, and across Europe.
Given the nature of Tide’s business, we believe there is a low risk of modern slavery and human tracking existing in our business operations or supply chains, and take a zero-tolerance approach to these real, yet often hidden, issues in our society.
Tide’s Board and the Executive Management Team maintain transparent relationships with the regulators, which ensures our strategic aims are in line with our regulatory obligations, board members are subject to FCA’s Senior Managers and Certification Regime Conduct Rules and are screened for Conflicts of Interest.
Our governance framework allows for effective flow of information through appropriately structured executive committees. Key issues, including those related to human rights, may therefore be raised through these channels to the Board.
We do not provide banking services or invest in organisations that use excessive power to systemically promote public behaviour which is harmful to individuals, groups or society as a whole.
Our Key Values & Ethics
At the heart of our company are three core values: Members First, One Team, and Data Driven. These principles shape not only how we work together internally, but also how we engage with our members, suppliers, and the wider community.
Members First means we are committed to acting in the best interests of our members at all times. Their needs drive our decisions, and their wellbeing is central to our purpose.
One Team reflects our belief in collaboration, respect, and accountability. We work together across departments, partners, and suppliers to create a positive and ethical working environment for all.
Data Driven underlines our commitment to making informed, transparent, and responsible decisions. We use insights to continuously improve and to identify areas where we can do better, especially in our ethical and social responsibilities.
We are passionate about supporting businesses and individuals in a way that upholds human rights and promotes fairness, dignity, and opportunity. These values are embedded in our culture and guide us in identifying, preventing and addressing the risks of modern slavery and exploitation in any part of our operations or supply chains.
We believe that ethical business is good business, and we are committed to ensuring that everyone connected with our organisation is treated with respect and fairness.
The following sections show how these values translate into our approach with our employees, our members, and the third parties we work with.
Our employees: Tideans
We are dedicated to treating all employees fairly and equally, helping them to perform at their best. Our goal is for our rules and procedures to ensure all Tideans are acting with the utmost conduct and understand what is expected of them.
Our culture is one where employees treat their colleagues with dignity and respect, creating an inclusive environment. We do not tolerate discrimination, bullying, or harassment on any grounds, as outlined in our Code of Conduct, Disciplinary Policy, Procedure Policy on Prevention of Sexual Harassment at Workplace, and other related policies.
Underpinning all these policies is our commitment to listening to our employees' voices. We strive to maintain a culture where our employees can raise concerns without fear of retaliation. We encourage feedback and provide effective and confidential channels for employee complaints, including our whistleblowing policy and procedures, which include access to a dedicated helpline to protect the identity of whistleblowers, managed by Syntrio.
Tide’s Financial Crime Policies apply to all members, employees, and third parties, including suppliers. These policies cover all financial crime types, including fraud, bribery and corruption, tax evasion, sanctions, money laundering, and terrorist financing. They are designed to mitigate the risk when we initiate or continue relationships with account holders or entities involved in criminal activity.
Training & Development Programme
We are dedicated to continuously training our employees to ensure they have the necessary tools and knowledge to be eective in their roles. All new Tideans receive financial crime training, which is refreshed annually. We also provide training conducted by external experts to help our teams identify signs of modern slavery or human tracking in our members.
Our commitment includes:
- Comprehensive Training Programmes: We provide regular training sessions for all employees to ensure they can recognise the signs of modern slavery and human tracking. This training is mandatory and covers case studies, identification techniques, and reporting procedures.
- Continuous Development: We regularly update our training materials with the latest information and best practices. All training material is reviewed annually to support continuous development.
We will continue to review our efforts to combat modern slavery and human tracking, as well as the controls and monitoring systems in place, with the dedication to making necessary improvements to our policies and practices.
Measuring Effectiveness
Area | Metrics | 2024 Result |
|---|
| % of colleagues who completed financial crime training including modern slavery | |
Our Customers: Tide Members
Tide verifies every member’s identity and assesses their risk profile when they join, and we continue to monitor this over time. If we detect signs of increased risk or suspicious activity—including relating to modern slavery—we carry out enhanced checks and take action in line with our legal obligations.
Modern slavery and human tracking are serious crimes, and any financial gains from them are treated as criminal proceeds. At Tide, we are fully committed to preventing our services from being used to facilitate or support such activity.
We’re also continually strengthening and enhancing our Financial Crime Framework to ensure our teams have the tools and training needed to identify and prevent financial crime, which includes modern slavery and human tracking.
Over the past twelve months, we have continued to improve our financial crime controls, ensuring that we are fully compliant with our regulatory obligations and protecting our members.
We have worked hard to :
- Improve the identification of red flags that are indicative of Modern Slavery, Human Tracking and Sexual Exploitation by enhancing how we identify both victims and perpetrators of labour and sexual exploitation.
- Ensure our Financial Crime team proactively assess our member base for exposure to modern slavery and human tracking, and ensure we raise investigations and Suspicious Activity Reports to the National Crime Agency, which gives law enforcement timely and actionable intelligence so they can better identify victims and pursue perpetrators.
Measuring Effectiveness
Area | Number of MS & HT SARs |
|---|
Suspicious Activity Reporting - related to modern slavery & human tracking | |
Our Third Parties: Partners, Suppliers and Outsourcing
Tide is dedicated to establishing strong business relationships with high-quality suppliers and partners who uphold ethical standards that are equivalent to Tide’s own. This includes the fair treatment of customers, employees, and other stakeholders. Tide primarily uses services from third parties in the United Kingdom, Europe and India.
To address tracking and slavery in the supply chain, we:
- Have high expectations in our partner relationships. These are our deepest and most important third party relationships. Tide ensures that all partners meet the high standards we uphold as a company. We verify that modern slavery statements are in place with our strategic partners both during onboarding and on an ongoing basis.
- Carry out due diligence and oversee relationships in line with our Outsourcing and Vendor Risk Policies and relevant procedures. This helps us ensure that third parties meet, and continue to meet, Tide���s expectations.
- Adopt a risk-based approach to identify, monitor, and assess suppliers who are at a higher risk of being involved in instances of slavery/ tracking within our due diligence, and take appropriate mitigating actions.
- Integration of Anti-Slavery Obligations: For any high-risk suppliers, we include specific anti-slavery clauses in our contracts. These clauses require compliance with the Modern Slavery Act and outline consequences for non-compliance, including contract termination.
Material outsourcing decisions are made by the Board on the recommendation of the Board Risk & Compliance Committee, and the materiality of Tide’s outsourcing relationships are regularly monitored. Upholding high standards of business conduct is crucial to Tide, and we do not engage with vendors that violate labour laws.
Checking our Progress on Our Modern Slavery Commitments
We are committed to continually reviewing the steps we are taking, as well as the controls and monitoring systems we have in place, to combat modern slavery and human tracking. In previous statements we have made commitments in this regard, various improvements to our policies and practices, and the below is an update on our progress.
The financial crime investigations team will continue proactively investigating our member base. We will focus on members operating in high-risk industries or working with suppliers in jurisdictions linked to human tracking and modern slavery. Where we identify suspicious activity, we’ll apply enhanced monitoring and file the appropriate reports.
In 2024 We Committed to: | Where We Are | Our Next Steps |
|---|
Introducing a Modern Slavery and Human Tracking Policy. | Modern Slavery and Human Tracking policies and expectations are now included within Financial Crime policies for all regions, as well as associated and other relevant procedures. | The key next step in this space is to define Tide’s global approach to Financial Crime, which will include Modern Slavery and Human Tracking requirements, and to update our global approaches to meet these standards. Further, we will review and improve our approach and expectations around outsourcing and understanding fourth party risks. |
Conducting Internal Audits to assess our compliance with modern slavery policies, with high risk findings reported to relevant governance committees. | Internal Audit Team provides an annual independent assurance of Tide’s Financial Crime Compliance Framework including compliance with modern slavery. All recommendations are raised in our internal governance forums and improvement plans are tracked accordingly. | In Q2 2025, the Internal Audit function conducted a detailed review of the Modern Slavery controls and the report is to be finalised in July. |
We will strengthen our confidential reporting mechanism for employees and stakeholders to report any concerns related to modern slavery. Once raised, all reports will be thoroughly investigated, and appropriate action will be taken. | During 2024, no such concerns have been reported. However, the channels are in place. | Tide is working to develop its Speak Up culture, to ensure all Tideans feel empowered to raise concerns and challenges related to modern slavery (or anything else). |
We will conduct awareness campaigns to educate our members about the risks of modern slavery and human tracking within their supply chains. These campaigns will utilise various channels such as newsletters and social media blog posts. | Tide’s first Modern Slavery themed blog post is to be launched in conjunction with the publication of this statement. | Tide will continue to promote awareness of modern slavery and other related issues to support our members in dealing with some of the biggest contemporary challenges for business. |
We will provide our employees and members with resources and tools to help them identify and mitigate the risks of modern slavery. This includes checklists and access to expert advice. | Tide is continuously improving its Financial Crime Framework to make sure our teams have the right tools and training to detect and prevent financial crime, including modern slavery and human tracking. We regularly update our business-wide financial crime risk assessment and test our controls to ensure we’re effectively managing risk, meeting regulatory requirements, and strengthening controls in our most vulnerable areas. | The financial crime investigations team will continue proactively investigating our member base. We will focus on members operating in high-risk industries or working with suppliers in jurisdictions linked to human tracking and modern slavery. Where we identify suspicious activity, we’ll apply enhanced monitoring and file the appropriate reports. |
In terms of future commitments, Tide will:
1. Continue to improve our approach to screening for Human Tracking and Modern Slavery risks in our third party risk management, and in particular ensure we can evidence third party approaches to these risks wherever a relevant activity is being outsourced by Tide.
2. Continue to strengthen our financial crime framework and internal control environment, which includes proactively investigating our member base. The dedicated Financial Crime team will focus on members operating in high-risk industries or working with suppliers in jurisdictions linked to human tracking and modern slavery to ensure we are identifying and reporting suspicious activity.
As above, we will monitor and update our progress in meeting these commitments in future statements.
Board Approval
This statement was approved by the Board of Directors of Tide Holdings Limited on 24 July 2025
Oliver Prill
CEO
Date: 24 July 2025
