Modern slavery statement

Modern slavery is a crime and a violation of human rights. It covers slavery, servitude, forced or compulsory labour and human trafficking. Opal Paye Limited does not tolerate it in any part of our business or our supply chains, and we expect the same standard from everyone we work with.

This statement covers our financial year, July 2026 to July 2027, and was approved on 21 October 2026.

1. About this statement

We publish this statement voluntarily. Section 54 of the Modern Slavery Act 2015 requires a statement from organisations with an annual turnover of £36 million or more, and our turnover is below that threshold. We publish one anyway, because our agency and end client partners expect it, because we work in sectors where vulnerable people are placed into work, and because it is the right thing to do.

We will review and republish this statement every year.

2. Our business and supply chains

Opal Paye Limited is a UK payroll and umbrella company. We employ workers who carry out temporary assignments arranged by recruitment agencies, and we run their payroll: calculating pay, making statutory deductions, paying wages and handling pension auto-enrolment.

We do not find work for people ourselves, and we do not operate outside the UK. Our supply chain is short and made up of:

• the recruitment agencies that place workers with us
• the end clients those workers are assigned to, including schools, local authorities and private sector employers
• our payroll software provider, Nxsys
• our workplace pension provider, Smart Pension
• our bank, accountants, insurers and professional advisers
• our IT, website and email suppliers, including GoDaddy and Cloudflare

3. Where the risks are

We have assessed where modern slavery is most likely to touch our business. Because we pay people rather than place them, our greatest exposure is to workers who reach us through someone else. The risks we take most seriously are:

• Controlled bank accounts. Wages being directed to an account belonging to someone other than the worker, a well-known sign of labour exploitation and debt bondage.
• Identity and right to work fraud. Documents being used by, or on behalf of, someone other than the person doing the work.
• Unlawful deductions and unpaid wages. Workers being charged fees, or losing pay to deductions they did not agree to.
• Vulnerable workers. People who do not speak English as a first language, or who are new to the UK, who may not know what they are entitled to.
• Third party pressure. A worker whose registration, timesheets or queries are always handled by someone else.

4. Our policies

The following policies support this statement and are available to our workers and staff:

• Whistleblowing policy, so that concerns can be raised without fear
• Anti-bullying and harassment policy
• Sexual harassment policy
• Diversity, equity and inclusion policy
• Health and safety policy
• Privacy notice
• Expenses policy, which sets out exactly what may and may not be deducted

All of these are published at www.opalpaye.co.uk/policies.

5. What we do about it

Checks before anyone starts

• We verify every worker’s right to work in the UK before their employment starts, using original documents or the government online checking service.
• We pay wages only into a bank account in the worker’s own name. We do not pay a worker’s wages to a third party.
• We check for duplicate bank details, addresses and contact numbers across our payroll. Repeats are investigated before any payment is made.
• We contract directly with each worker. There is never another intermediary between us.

Transparency about pay

• Every worker receives a key information document before they agree to an assignment, showing their pay, deductions and our margin.
• Every payslip itemises gross pay, holiday pay, tax, National Insurance, pension and our margin, so nothing is hidden.
• We never charge a worker a fee for finding or keeping work.
• Workers can see all of their pay documents at any time in their online account.

Who we work with

• We expect the recruitment agencies that place workers with us to carry out their own right to work and identity checks, and to meet the Conduct Regulations.
• We will end a relationship with any agency or client that will not take a credible concern seriously.

6. Training and awareness

Everyone who deals with workers or payroll is briefed on the signs of labour exploitation: wages going to someone else’s account, repeated addresses or phone numbers, a third party speaking for a worker, reluctance to discuss pay, or a worker who does not know what they are being paid.

This training is delivered at induction and annually thereafter.

Our staff know to escalate a concern immediately rather than wait for proof.

7. How we measure whether this works

For the coming year we will track:

• the number of right to work checks completed before employment starts, which should be every worker, every time
• the number of duplicate bank account or address matches found, and what happened in each case
• the number of concerns raised by workers, staff or agencies, and how quickly each was dealt with
• whether every worker received a key information document before starting
• completion of modern slavery awareness training across our team

8. Raising a concern

If you work with us or for us and something does not look right, tell us. You do not need to be certain, and you will not be penalised for raising a concern in good faith.

Email	payroll@opalpaye.co.uk
Phone	01772 974162
Modern Slavery & Exploitation Helpline	08000 121 700, open 8am to 6pm, seven days a week
In an emergency	Call 999

Concerns can also be reported to the Gangmasters and Labour Abuse Authority, which investigates labour exploitation in the UK.

9. Approval

This statement was approved by the board of directors of Opal Paye Limited on 21 October 2026 and is signed on its behalf.

Signed
Name	Michael Shorrock
Job title	Managing Director
Date	21 October 2026

Opal Paye Limited. Registered in England and Wales, company number 15769485. Registered office: Unit 11, Ground Floor, Bartle Court, Rosemary Lane, Bartle, Preston, Lancashire, PR4 0HF.