Modern Slavery Statement

on behalf of Treatwell Limited

Treatwell’s position on slavery

Treatwell’s continues to maintain a zero-tolerance policy towards modern slavery. Modern slavery is a serious crime and a violation of basic human rights, manifesting in forms like slavery, servitude, forced labor, and human trafficking. This goes against the ethos of Treatwell, which is dedicated to fairness, equality and respect for all.

Treatwell has continued to conduct our business with the highest ethical standards and integrity. We have policies, procedures, and training programs designed to prevent modern slavery within our operations, in the salons we work with (“Salon Partners”), and across our supply chains. All concerns raised will be thoroughly investigated, and appropriate actions will be taken to prevent modern slavery. We recognize our unique position to raise awareness of this issue and to educate our customers, Salon Partners, their employees, and our own staff on how to prevent it from occurring in the industry. We expect the same high standards from all of our Salon Partners, third-party suppliers, and other business associates.

Our commitment to transparency extends across our business and in our efforts to combat modern slavery within our supply chains and among our Salon Partners, in line with our obligations under the Modern Slavery Act 2015. As part of our contractual agreements, we enforce strict prohibitions against the use of forced, compulsory, or trafficked labor, or any form of slavery or servitude involving both adults and children, and we expect our Salon Partners and third-party suppliers to implement similar safeguards within their own supply chains.

Due diligence

It is incredibly important for us to only partner with Salon Partners who work to the highest industry standards and are reputable within the hair and beauty space. We ask all of our Salon Partners to commit to our Partner Terms of Business which set out everything that we expect from them before we allow them on our site, including active measures to prevent modern slavery.

All of our Salon Partners warrant to us that, among other things, neither they nor their employees, directors, officers or subcontractors have been investigated for, or convicted of, any offence around slavery or human trafficking, and that they have made all reasonable enquiries on the same. They are also required to maintain policies and procedures to ensure that they comply with their obligations under all anti-slavery laws.

We have a detailed on-boarding process that we undertake before any Salon Partner can be listed on Treatwell. This includes (1) in-person salon visits to those offering certain treatments, (2) obtaining insurance documentation and licences where applicable and (3) various other know-your-client and verification checks. Ultimately, we want to ensure that we have reputable Salon Partners on site offering the highest standard of service and operating at all times within the law. This extends to the staff that they employ, how they run their business and the importance of anti-slavery and anti-human trafficking measures. If at any time a Salon Partner does not operate within the law, that is a material breach of their agreement with us, and we would terminate our partnership with them.  Furthermore, we would report the issue to the Modern Slavery Helpline for them to investigate and take necessary action.

In 2024, we carried out the following measures to reinforce our means of vetting Salon Partners that join Treatwell:

  • Online verification of identity: This was done as part of mandatory vetting of vendors pursuant to the Revised Payment Services Directive (PSD2) and DAC7. This included verifying personal data of the business owners, conducting a corporate KYC assessment. This has allowed Treatwell to conduct a risk assessment of the businesses based on factors such as type of business, transaction volume, and customer trends.
  • Adherence to the Treatwell Anti-Modern Slavery statement. In 2024, we launched a self-sign up process for new Salon Partners. An important step in this process is ensuring that.

Policies, procedures & training

Our current policies, procedures and training to tackle modern slavery and human trafficking in our supply chains, our Salon Partners and our business include:

  • Annually informing all employees of Treatwell’s and their own obligations in relation to modern slavery and regularly remind them of our internal communication channel which employees can use to confidentially detail their concerns if they feel that there is an ethical issue we should be made aware of and investigate. All employees are encouraged to make use of this should they feel they need to and are protected in doing so under our Whistleblowing Policy;
  • Providing ongoing training to our employees by inviting the London Metropolitan Police to educate employees about the dangers posed within our industry;
  • Providing guidance to Salon Partners to educate them and their employees on modern slavery and provide a procedure to follow to raise any concerns with us and with the official bodies tackling modern slavery;
  • Report issues to the Modern Slavery Helpline, either directly or by encouraging the individual who has raised the concern to do so, whether a Salon Partner, their employee, a customer or indeed one of our own employees, whilst disclosing that the salon in question is listed on Treatwell and offering our support in helping with the investigations;
  • Remove any salon where we have received a complaint about modern slavery which is corroborated by our own investigation and/or investigations by the Modern Slavery Helpline and/or investigations by the police; and
  • Register with the Central Registry for business transparency and the government’s Modern Slavery Registry and published this statement within both platforms. As an authenticated organisation, we are able to access specialist tools and information to help continuously build on our statement whilst supporting wider efforts to tackle modern slavery in the UK.

What next?

We're absolutely dedicated to these measures and to constantly improving our approach to tackling modern slavery. We'll keep a close eye on changes in laws and industry practices to see how they impact our anti-slavery efforts and take decisive action to prevent and stop any cases we discover. You can count on us to do more research, speak up louder, and take tougher steps in our passionate fight against modern slavery.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2024. This statement has been approved by Treatwell Limited's board of directors on 26 November 2024.

Signed by Director of Treatwell Limited Tobias Hinteregger on 26 November 2024.