Modern Slavery Statement

1. Purpose and zero-tolerance stance
Modern slavery is a severe violation of fundamental human rights and can take many forms, including child labour, slavery, servitude, human trafficking and forced labour. [Company Name] adopts a zero-tolerance approach to all forms of modern slavery and human trafficking and is committed to acting ethically and with integrity in all business dealings and relationships.
2. Scope and applicability
This Statement applies to [Company Name], its subsidiaries and controlled affiliates, and to all persons working for or on behalf of the company (employees, officers, temporary staff, contractors, suppliers and other third parties) across all jurisdictions in which we operate.
3. Our business and supply chains
[Company Name] operates as a financial technology group providing cross-border payments and related services. We engage with a range of counterparties, including financial institutions, technology vendors and professional service providers. We require all third parties in our supply chain to uphold standards on human rights and labour consistent with this Statement and applicable law.
4. Governance and accountabilityBoard oversight: The Board (or a delegated committee) approves this Statement and oversees its implementation.Executive responsibility: Senior management is responsible for embedding controls, monitoring effectiveness and reporting material issues.Policies: This Statement is supported by our Code of Conduct, Third-Party Risk Management Policy, Procurement Policy, Whistleblowing/Speak-Up Policy, and AML/CTF and Sanctions frameworks.
5. Risk assessment & due diligence
We apply a risk-based approach to identify, assess and mitigate modern slavery risks in our operations and supply chains, including:Country and sector risk screening for new and existing suppliers.Supplier due diligence proportionate to risk, covering ownership, labour practices, recruitment fees, and subcontracting.Contractual safeguards (warranties, audit rights, immediate termination for breach).Ongoing monitoring through attestations, adverse-media checks and trigger-event reviews.Escalation protocols where indicators of forced labour or trafficking are identified.
6. Supplier standards
Suppliers and partners must:Prohibit forced, bonded or involuntary labour, child labour and human trafficking.Ensure freely chosen employment, freedom of movement and no retention of identity documents.Pay at least legal minimum wages, provide lawful working hours and safe, hygienic workplaces.Prohibit recruitment fees charged to workers and ensure transparent employment terms.Cascade these standards to their own supply chains and cooperate with audits or investigations.
7. Training and awarenessInduction and periodic refreshers for employees and contingent workers on recognising red flags, responsible procurement, and reporting channels.Targeted training for procurement, vendor management, onboarding/compliance, and high-exposure roles.Guidance materials (checklists and escalation pathways) available to all staff.
8. Reporting, investigations and remediationConcerns about potential modern slavery may be raised via internal speak-up channels or to management. Anonymous reporting is supported where permitted by law.Reports are assessed promptly; credible allegations trigger a formal investigation.Remediation: Where impacts are identified, we work to protect affected individuals, engage specialists where appropriate, and address root causes with the supplier/partner.Enforcement: Confirmed violations may result in contract suspension or termination and notification to competent authorities.
9. Measuring effectiveness (KPIs)
We track and review:Percentage of in-scope suppliers risk-screened and attested annually.Completion rates for modern-slavery training in high-risk functions.Number and status of investigations, outcomes and remediation actions.Audit findings and corrective-action closure within agreed timelines.
10. Continuous improvement
We periodically review this Statement, our risk assessment, controls and training content to reflect evolving laws, guidance and best practice. Lessons learned from incidents, audits and stakeholder feedback inform program enhancements.
11. Approval and review cycle
This Statement has been approved by the Board of [Company Name] on [Insert date] and will be reviewed at least annually or sooner if required by law or material changes in our risk profile.