Otta Ltd is incorporated in the United Kingdom (UK) under reference number 11377564 with a registered address of 82 St John Street, London, United Kingdom, EC1M 4JN. Otta Ltd also has the trading name of “Aslan”.
Aslan is operating as an E-Money Directive (EMD) Distributor under Monavate Limited. Monavate Limited operates as an Authorised Electronic Money Institution with the UK Financial Conduct Authority (FCA) under firm reference number 901097.
Aslan is a financial wellbeing solution provided to businesses for their employees. Our mission is to transform the financial lives of employees, ensuring an engaged, happy, and productive workforce for employers.
This policy details Aslan’s approach to human rights, modern slavery and human trafficking, how we are guided, our responsibilities and remedies.
This Policy shall be deemed effective only upon approval by Senior Management. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This policy applies to all employees, contractors, partners, clients and suppliers.
This document shall be subject to periodic reviews in accordance with changes in:
Local and international legislation.
Industry best practice.
Internal changes in the business that impact the products available and relevant revenue streams.
Senior Management review and approve all changes before they are implemented. Minor changes are reflected by incrementing the version number as 1.1, 1.2, 1.3, etc.
Where significant changes to the document are made, these are reflected in a new version number as 1.0, 2.0, 3.0, etc.
At Aslan, we believe that our business can only thrive when human rights are protected and respected. Upholding these rights isn’t just a legal or ethical requirement—it’s fundamental to who we are as a company and how we operate in the world.
We’re guided by the UN Guiding Principles on Business and Human Rights, the conventions of the International Labour Organisation (ILO) and the UK Modern Slavery Act 2015. We are committed to respecting all internationally recognised human rights that are relevant to our operations.
When there’s a difference between national laws and international human rights standards, we will always strive to adhere to the higher standard. If there’s a conflict, we’ll follow national laws while seeking ways to honour international human rights as much as possible.
We do not tolerate human trafficking or modern slavery within our organisation or our supply chain and, while, as a financial wellbeing solution, we have a limited risk of this occurring across our organisation, we have included within this policy coverage of any potential areas where this risk may occur.
Respecting human rights isn’t a one-time task; it’s an ongoing responsibility. We pay special attention to critical moments in our business activities, such as forming new partnerships, hiring employees or changing our operations. These situations may present new risks or impacts on human rights, and we are committed to addressing them proactively.
Our business is set to grow quickly. We recognise that the foundations we lay now are crucial for future-proofing our company. This means that even at our current size, we take special care to adhere to these human rights principles, ensuring that they remain a core part of our company culture as we expand. By embedding these values from the beginning, we aim to build a business that scales responsibly and ethically.
We know the importance of open communication. We make it a priority to keep our employees and external partners informed and educated on our policies and business practice. Especially those who might be more vulnerable to human rights risks. We are committed to listening to and addressing any concerns that may arise.
Aslan ensures that employees and suppliers read and accept this policy at onboarding.
We are committed to inclusive recruitment and internal mobility best practice, and have implemented TalentMapper, a recruitment and employee-enablement software system to help remove bias from external and internal hiring processes. We expect other Aslan stakeholders to embrace this commitment as well.
Discrimination, modern slavery, forced labour, human trafficking, and child labour have no place in our operations. We are dedicated to providing safe and hygienic working conditions, respecting the dignity of every individual, and upholding the rights to freedom of association, collective bargaining, and effective communication. Our staff are well paid (well above the UK’s living wage) and we ensure that working hours are reasonable.
Aslan operates a rigorous recruitment process for all employees, including referencing and obtaining proof of Right to Work documents in the country in which they will be employed.
We 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 client and supplier portfolio is diverse, and we recognise the role our clients play in the success of our business and suppliers in helping our business operate successfully. We run due diligence and adverse media checks on all our clients and suppliers to assess potential misaligned values regarding respect for human rights, including labour rights and links to modern slavery or human trafficking
We are committed to identifying and addressing any potential or actual adverse impacts on human rights, whether directly through our activities or indirectly through our business relationships.
When human rights issues arise, we are committed to ensuring effective remedy. We encourage open and honest communication within Aslan and with our suppliers, clients and stakeholders. Anyone can raise concerns without fear of retribution, using our traditional contact channels. We take every issue seriously, review it thoroughly, and take appropriate action.
Policy breaches will be escalated to the Chief Compliance Officer immediately. When it is determined that a breach of this policy has occurred, Aslan 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.
