Human Rights Policy

1. Introduction and Purpose

Pollinate is a family of very talented and hard-working professionals on a mission to reconnect banks, businesses, and communities through payments. We recognise that, to achieve this, we must adhere to the highest possible standards in everything we do, including respecting human rights and ensuring that all individuals are treated with dignity and respect.

This policy sets out our commitment and the steps we take to meet our responsibility to respect internationally recognised human rights standards. It is guided by the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. Pollinate complies with national laws and regulations in the jurisdictions within which it operates.

In the event of a conflict between national laws and regulations and international human rights standards, Pollinate will always seek to implement processes that respect those international human rights standards. This policy provides the basis for embedding responsibility to respect human rights throughout all of our business functions and applies not only to Pollinate, but also to its subsidiary companies, employees, contractors, suppliers, agents and any other third party working with us as part of our operations. This policy is approved and overseen by the Pollinate Executive Team.

2. Our Supply Chain

We expect our third-party suppliers and partners to adhere to the highest standards of quality and integrity in all aspects of their business. Furthermore, we carry out appropriate due diligence before working with a new supplier and we audit our suppliers to monitor their compliance with our policies and ethical standards.

3. Diversity Inclusion and Equal Opportunities

Pollinate Diversity and Inclusion Statement:

“We are committed to equality and inclusivity with our people. The diversity of our backgrounds, beliefs and experience brings out the best in us and allows us to create a company that leads through innovation. Our differences are a cause for celebration, they define us and support our drive, creativity and passion.”

We are committed to equality and inclusivity with all of our people. We want wherever we work to be a fantastic space where people feel able to participate, share ideas and inspire each other. We have a Code of Conduct (which all employees accept as part of basic training) as a guideline to ensure that we are all working towards the same goal. We would expect everyone to adhere to this code at any time they are working in the Pollinate environment, however, it also applies wherever we are representing Pollinate externally.

At Pollinate we believe that people have a right to be treated with dignity. Pollinate is committed to providing a working environment free from harassment and bullying and ensuring all employees are treated, and treat others, with dignity and respect. Any issues within Pollinate can be raised through our robust Grievance Procedure.

4. Health and Safety in Workplace

We are committed to ensuring the highest standards for health and safety of employees and anyone affected by our business activities, and to providing a safe and suitable environment for employees and all those attending our premises. All employees share the responsibility of achieving safe working conditions and we are committed to engaging with employees to continually review and improve health and safety in our workplaces.

Employees are provided with appropriate training and required to take care of their own health and safety and that of others, observe applicable safety rules and follow instructions for the safe use of equipment. Employees are also required to report any health and safety concerns immediately and to co-operate on health and safety matters, including the investigation of any incident.

5. Forced Labour, Human Trafficking, Modern Slavery and Child Labour

Pollinate is committed to acting ethically and with integrity in all our business dealings and relationships in concurrence with implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chains. There is no forced, bonded or involuntary prison labour used in any part of Pollinate. Employees and workers are not required to lodge “deposits” or their identity papers and are free to leave their employment after reasonable notice is given in accordance with their contract. Identity papers may be checked to ensure we comply with our legal obligation to ensure individuals have the right to work in the UK but these are always returned.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our obligations under the Modern Slavery Act 2015. We expect the same high standards from our contractors, suppliers, and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect that our suppliers will hold their own suppliers to the same high standards.

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Pollinate does not employ anyone under the age of 18 years of age (unless employed as part of an apprenticeship scheme where the minimum age will be 16 years of age) and there are robust processes and systems in place to ensure this is the case.

We have zero tolerance for slavery and human trafficking in any part of our business, including our supply chains. We have a number of policies in place to ensure all our employees have the right to work and are paid fairly, that we act with integrity and ethically, and that we have effective measures in place to ensure slavery is not present anywhere in our business or supply chain.

6. Treatment of Workers

Pollinate will not accept:

  • Violence in Any Form – whether this is verbal, physical or the threat of violence. It is completely unacceptable. Nobody should be subjected to any form of violence – either online or in person. This includes but is not limited to personal attacks and derogatory statements about an individual.
  • Discrimination or Derogatory Language – we celebrate our differences here at Pollinate and will not tolerate any form of discrimination or derogatory language towards any individual or group. This includes but is not limited to; background, family status, gender identity or expression, sexual orientation, native language, age, ability, race or ethnicity, national origin, socioeconomic status, religion or any other attributes.
  • Sexual or Physical Harassment – unwelcome sexual attention or physical contact is not acceptable and will be dealt with quickly and fairly. This includes but is not limited to, verbal harassment such as innuendo or suggestive language, inappropriate touching, groping, sexual advances, touching somebody without permission, physically blocking, simulated physical contact (emojis) as well as sharing or distributing sexualised content.

7. Wages, Benefits and Working Hours

We compensate employees competitively relative to the industry and local labour market. We ensure full compliance with applicable wage, work hours, overtime, and benefits laws (including but not limited to the laws applicable to the national minimum and living wage). In any event, wages should always be enough to meet the basic needs and provide some discretionary income. All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment, and about the particulars of their wages for the period concerned each time that they are paid. Deductions from basic wages as a disciplinary measure is not permitted; nor are any deductions from wages not provided for by national law, without the express permission of the worker concerned.

Working hours will be defined by contract. Workers may be offered overtime hours from time to time, but there is no obligation to work any overtime, unless covered by local collective bargaining agreements. Workers are given the option of opting out of the Working Time 48 hour regulations, but this is a voluntary decision. Overtime shall be used responsibly, taking into account the extent and frequency of the hours worked by individual workers and the workforce as a whole. Appropriate safeguards are always taken to protect the worker’s health and safety. Overtime shall not be used to replace regular employment and shall always be compensated for appropriately.

Employment relationships are based on established national laws and practices. Obligations to employees under applicable social security regulations, and apprentices’ schemes, are entered into with a full undertaking to carry these out. Excessive use of fixed-term contracts for the purposes of avoiding employee rights and benefits is not permitted.

8. Freedom of Association and Collective Bargaining

Pollinate prides ourselves on honest and direct communication with our employees and will continue to put this at the forefront of our culture. We recognise our employee’s rights to join or form trade unions, and to bargain collectively as permitted by national laws. These rights will not be restricted or interfered with. Pollinate adopts an open attitude towards the activities of trade unions and their organisational activities. Workers’ representatives are not discriminated against and have the ability to carry out their representative functions in the workplace. Where the right to freedom of association and collective bargaining is restricted by law, we will facilitate, and not hinder, the development of parallel means for independent and free association and bargaining.

9. Communication and Review

Pollinate undertakes to ensure that its Human Rights Policy is communicated effectively to all relevant employees, contractors, suppliers, agents and any other third party working with us as part of our operations.

Pollinate strives to create an open and honest working environment in which everyone’s views are valued and respected. All employees can raise any concerns they have regarding any human rights violations without fear of reprisal. Any customer with concerns regarding Pollinate’s activities and compliance with our Human Rights Policy or legal obligations can raise these through our customer service channels. This policy shall be reviewed annually and updated as and when necessary, to reflect changes in relevant legislation and improvements in approach.
Pollinate’s People Team have direct responsibility for maintaining this policy and providing information and guidance on its implementation.

OHCHR | International Bill of Human Rights
GuidingPrinciplesBusinessHR_EN.pdf (

The Human Rights Policy was last updated on 1st November 2022.

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