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Introduction

The UK Modern Slavery Act 2015 requires certain companies carrying on a business that supplies goods or services from or to the UK to publish a statement describing the steps taken to ensure modern forms of slavery are not taking place in the company’s business operations and supply chains.

The term "modern slavery" is used to describe situations where a person is deprived of their liberty in order to exploit them for personal or commercial gain. It is a criminal offence, a violation of human rights and can take a number of forms, including: slavery, forced or compulsory labour, servitude, human trafficking, and trafficking for prostitution or sexual exploitation. 

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015. It outlines the steps that �������� has taken, and will continue to take, to ensure neither modern slavery nor human trafficking is practiced within its business operations or by its suppliers and constitutes ��������’s modern slavery statement for the financial year ending 2024.

About ��������

�������� is a group of affiliate companies that provide payment, connected commerce and VAT refunding services in the experience economy for our customers in retail, hospitality, VAT refunds and property managed services. 

While �������� takes similar steps globally, this statement applies to  (“PMSL”), a company authorized to provide payment services by the Financial Conduct Authority (FCA) as a payment institution with company number 08791017 and to  (“PPUKL”), a company incorporated in the UK with company number 02076853.

��������’s Modern Slavery Risks

�������� recognises that modern slavery is a significant global issue which can occur anywhere, not just in developing countries and economies, and for this reason �������� has carried out a review of the systems and processes that it has in place to understand where the potential risks in terms of modern slavery are located. 

Based on this review, and considering its business model and geographical footprint, �������� has assessed that its modern slavery risk would mainly come by suppliers as follows:

• Technology companies providing hardware, software and data centres;
• Outsourced service providers that provide equipment and services for its employees and offices; and,
• Companies that provide professional services, such as legal, financial and consulting services.

The conclusion of this assessment has allowed �������� to understand that the majority of ��������’s products and services are mainly operated with the assistance of regional suppliers and primarily local ��������’s employees and for this reason �������� faces a lower risk of modern slavery. 

Notwithstanding, �������� acknowledges that a continuous review of its supply chain and operations is vital to reduce the possibility that any of its business activities contribute to or facilitate modern slavery.

��������’s Commitment to Modern Slavery

�������� is committed to the principles and provisions of the Modern Slavery Act, by ensuring that its business operations and supply chains are free from modern slavery. In this sense, �������� takes a zero-tolerance approach to modern slavery and will not knowingly support or deal with any business or supplier involved in such practices.

��������’s commitment to addressing Modern Slavery risks is structured in three different foundations:

• Policy framework;
• Supply chain management; and,
• Training and awareness.

Policy Framework

�������� has a comprehensive set of policies, systems and procedures that contribute towards the mitigation of the modern slavery risks which �������� may face as part of its business operations. These policies set out how �������� operates, its values and expectations of its staff and suppliers, and are reviewed and refreshed on an annual basis.

This policy framework ensures that ��������’s employees and suppliers clearly understand its expectations, and also how �������� deals with behaviour and actions which are inconsistent with these expectations.

The following policies are those that are most relevant to mitigating modern slavery risk in its business operations and setting appropriate expectations among its employees and suppliers:

• �������� Modern Slavery Policy, which is the foundation of ��������’s modern slavery framework and outlines the ways in which �������� ensures that human rights are respected by:
  • Not tolerating modern slavery and human trafficking;
  • Committing to maintain and enforce effective systems and controls to prevent slavery and human trafficking;
  • Encouraging the detection and reporting of slavery in the event of issues or suspicions of modern slavery in any part of the company’s business or supply chain;
  • Ensuring compliance with all relevant laws and regulations in the markets �������� operates.
• �������� Code of Conduct, which helps to ensure that all �������� employees not only act in accordance with all relevant laws, but also with honesty, fairness and integrity. Further, this Code of Conduct underpins all of ��������’s business operations and promotes ethical business practices that mitigate the risk that any of ��������’s business operations contribute to modern slavery and any other human rights abuses.
• �������� Anti-Bribery & Corruption Group Policy, that defines the main principles to be followed to prevent and combat bribery and corruption within �������� and also sets out the escalation process and actions that need to be put in place in case of an event that may suppose a breach of such Policy.
• PMSL Anti-money Laundering and Counter Terrorist Financing Policy: PMSL understands that the prevention of money laundering and terrorism financing is a vital component of its efforts to mitigate modern slavery risks in its business. This policy sets a minimum standard that all �������� business units must meet.
• �������� Whistleblowing Policy, which encourages ethical conduct by providing mechanisms to report actual or suspected wrongdoing and explaining the processes by which a whistleblower may make an alert, how alerts are processed as well as escalated.

Supply Chain Management

��������’s contract management framework is one of the key ways in which �������� articulates its human rights expectations and mitigates the potential risk of modern slavery arising in its supply chain, ensuring that appropriate due diligence is performed on all new suppliers in ��������'s supply chain.

• �������� Modern Slavery Policy, which contains a clear set of expectations that suppliers, and their respective suppliers, that establish a relationship with �������� are expected to commit to. Such commitments are mainly focused on avoiding practices associated with modern slavery and human trafficking and any way of violation of human rights.
• �������� Procurement Policy, which articulates the framework for its relationship with suppliers by setting out the process for selecting, engaging and managing the relationship with suppliers. This Policy is supported by �������� Supplier Code of Conduct.
• �������� Supplier Code of Conduct, which sets out the expectations that suppliers must commit in relation to human rights, labour rights, workplace health and safety, environmental management and modern slavery. This Code has been incorporated into all supplier agreement templates and is mandatory for all suppliers wishing to establish a relationship with ��������.

Training and Awareness

�������� understands that one of the most effective tools for mitigating modern slavery risks is building awareness of modern slavery risks through education.

To achieve this objective, �������� has developed a Training Program for PMSL’s employees with the aim of:

• Helping to limit and handle its risks;
• Being compliant with regulatory obligations;
• Building competent staff; and,
• Developing a continuous learning and development approach.

Monitoring and Reporting

�������� is committed to continuously strengthening controls to identify and mitigate modern slavery risks and human trafficking in its business operations and supply chains, through refining its Policy Framework, training and awareness initiatives, and oversight activities.

Further, as part of its commitment to transparency and respect for human rights, �������� will report publicly its progress in the next annual Modern Slavery Act Statement.

Approval

This statement was reviewed and approved by PMSL’s and PPUKL’s Board of Directors, which review and approval is made on at least an annual basis.