The UK Modern Slavery Act 2015 (Act) introduced important provisions to help combat modern slavery, human trafficking and human right abuses (together Modern Slavery). At Pay.UK Limited (Pay.UK), we, together with our subsidiaries (Pay.UK Group), are committed to playing our part in helping to prevent any incident of Modern Slavery in our business. This statement is made pursuant to Section 54 of the Act and sets out the steps that the Pay.UK Group is taking to help to prevent any incidents of Modern Slavery occurring in our business.
The Pay.UK Group is regulated by the Bank of England and Payment Systems Regulator. Between May 2018 and July 2018, Pay.UK acquired the companies responsible for operating several retail payment systems (including the Bacs, Faster Payments, Image Clearing and Paper Cheques systems) together with Mobile Payments Service Company Ltd, UK Payments Administration Limited and UTSP Ltd.
The steps we have taken
Prior to their acquisition by Pay.UK, the Pay.UK Group companies were responsible for their own compliance with the Act. Those approaches included the use of contractual terms requiring third party suppliers to comply with the Act, due diligence questionnaires and provision of training to colleagues. Steps were also taken to better understand supply chains including assessments of likely Modern Slavery risk.
A review of existing policies and procedures has commenced to enable Pay.UK Group’s consolidated policies to be finalised and implemented. That review will leverage off the work already done by the Pay.UK Group companies on an individual basis. It will include additional analysis of the risk profile of our supply chain to help better inform our approach. The review will also focus on steps that can be taken to improve our due diligence processes (both at initiation of a new contract and on an on-going basis) and consider other ways that we can help prevent any incident of Modern Slavery in our business.