1. Introduction
This statement is made by Ecommpay Limited ("Ecommpay," "we," "us," or "our").
Our Board and Employees are committed to upholding the highest ethical standards as an organisation as well as when we’re working with our customers, partners and suppliers. We are also committed to upholding good practice standards in line with our ESG Strategy, and includes our focus to ensuring that slavery and human trafficking have no place in our business or supply chains. We recognise the importance of transparency and accountability in combatting these crimes. This statement outlines the steps we have taken, and continue to take, to prevent modern slavery and human trafficking within our operations and supply chains.
Ecommpay is a leading payment service provider and direct acquirer, headquartered in London, UK. Within our Group, we also have administrative, business support and technology services offices in Latvia, Cyprus and Kazakhstan. We provide payment solutions to online businesses globally, enabling them to accept payments online.
2. Our Business and Supply Chains
Ecommpay's core business involves providing online payment processing and merchant acquiring services. Our supply chains primarily consist of:
- Technology Providers: Companies that provide us with software, hardware, and infrastructure necessary for our payment processing platform. This includes data centres, network providers, and software developers.
- Financial Institutions: Banks and other financial institutions that are integral to the payment processing ecosystem (e.g., authorised credit institutions, banks, investment firms, card schemes).
- Commercial and Product Partners: Companies, platforms and persons who may refer business to us, or may provide services connected to our payment processing activities such as alternative payment method providers.
- Professional Services: Companies providing services such as legal counsel, auditing, consultancy, and recruitment.
- Office Suppliers: Companies providing office supplies, equipment, and cleaning services for our offices in London, Latvia, and Cyprus.
- Marketing and Advertising: Companies providing marketing, communications and public relation services.
We recognise that even within these seemingly low-risk categories, potential vulnerabilities to modern slavery can exist, particularly in areas such as outsourced services, cleaning, and lower-tier suppliers.
3. Our Policies on Slavery and Human Trafficking
Ecommpay is committed to acting ethically and with integrity in all our business dealings and relationships. We have implemented the following policies and procedures to mitigate the risk of modern slavery and human trafficking:
- Anti-Slavery and Human Trafficking Policy: Our internal policy prohibits the use of forced, bonded, or compulsory labor, and human trafficking in any part of our business or supply chains. It sets out our expectations for employees and suppliers. The policy is available to all employees and is regularly reviewed and updated.
- Whistleblowing Policy: We have a robust whistleblowing policy that encourages employees, suppliers, and other stakeholders to report any concerns, including those related to modern slavery and human trafficking, without fear of reprisal. We provide multiple channels for reporting, including confidential and anonymous options.
- Recruitment and Employment Practices: We adhere to fair recruitment practices and ensure compliance with all relevant employment laws in the UK, Latvia, Cyprus and Kazakhstan. This includes verifying the right to work of all employees, providing fair wages and benefits, and ensuring a safe and healthy working environment. We conduct background checks on all employees where applicable frameworks are in place.
- Employee Handbook: We communicate our stance on Anti Slavery and Human Trafficking within our employee handbook.
4. Due Diligence Processes
We understand that preventing modern slavery requires ongoing due diligence. We have implemented the following processes:
- Risk Assessment: We conduct regular risk assessments of our business and supply chains to identify areas where the risk of modern slavery and human trafficking may be higher. This assessment considers factors such as geographic location, industry sector, and the nature of the goods or services being provided. We specifically consider the risks associated with our operations in multiple jurisdictions.
- Supplier Due Diligence: For new suppliers, particularly those identified as higher risk, we conduct due diligence to assess their compliance with contractual commitments, relevant codes and their commitment to preventing modern slavery. This may include questionnaires, self-assessments, and, in some cases, on-site audits.
- Contractual Obligations: Our supplier contracts include clauses requiring compliance with all applicable laws. These clauses also grant us the right to audit suppliers and terminate contracts for non-compliance.
- Monitoring and Review: We continuously monitor our suppliers and our internal processes to ensure ongoing compliance. We regularly review the effectiveness of our due diligence procedures and make improvements as needed.
5. Training and Awareness
We recognise that raising awareness and providing training are crucial to preventing modern slavery. We are committed to:
- Employee Training: We provide training to relevant employees (e.g., those involved in procurement, HR, and management) on modern slavery and human trafficking, including how to identify potential risks and what steps to take if they have concerns.
- Supplier Awareness: We communicate our expectations regarding modern slavery and human trafficking to our suppliers and encourage them to provide training to their own employees and supply chains.
6. Key Performance Indicators (KPIs)
While we are not legally required to report on KPIs, we are committed to monitoring the effectiveness of our efforts.
7. Future Steps
Ecommpay is committed to continually improving our approach to combating modern slavery and human trafficking. In the coming year, we plan to:
- Enhance Supplier Due Diligence: Develop a more formalised and tiered approach to supplier due diligence, focusing on higher-risk suppliers.
- Strengthen Training: Expand our training program to include more in-depth modules and reach a wider range of employees.
- Collaboration with external parties on our ESG strategy: Explore opportunities to collaborate with other organisations in the payments industry to share best practices and address common challenges.
8. Approval
This statement has been approved by the Board of Directors of Ecommpay Limited.
Willem Wellinghoff, UK Chair
1 April 2025