2022 Modern Slavery Statement
Modern Slavery Statement
Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms and occurs when a person deprives another of their liberty in order to exploit them for personal or commercial gain.
At Pay.UK Limited (Pay.UK), we, together with our subsidiaries (Pay.UK Group), are committed to playing our part in helping prevent any incident of Modern Slavery in any part of our business.
We have a zero-tolerance approach to Modern Slavery and are committed to implementing, improving and enforcing effective systems and controls to make sure modern slavery and human trafficking is not taking place anywhere within our business or in any of our supply chains.
This is the fourth statement issued by Pay.UK in accordance with section 54(1) of the Modern Slavery Act 2015 (the Act) and applies to the Pay.UK financial year ending 31 December 2021. Our statement sets out the steps we take and have taken to help prevent and detect any incidents of Modern Slavery occurring within our business and was approved by the Pay. UK Board on 17 June 2022.
Pay.UK is the recognised operator and standards body for the UK’s retail interbank payment systems. We provide the digital payments networks used by the UK’s banks, building societies, other payment providers and all of their customers to make payments, ensuring they are secure, safe and simple to use.
Our organisation and structure
Under the Code of Practice published in accordance with section 189 of the Banking Act 2009, Pay.UK performs the role of the systemic risk manager for the payment systems we operate in order to support the financial stability.
Pay.UK Limited and Pay.UK Group are regulated by the Bank of England, Financial Markets Infrastructure Directorate (BoE-FMID) and the Payment Systems Regulator (PSR). We operate three of the UK’s interbank retail payment systems:
- the Bacs Payment System (Bacs);
- the Faster Payment System (FPS); and
- the Image Clearing System (ICS).
Both the Bacs and FPS are recognised by HM Treasury in accordance with section 184 of the Banking Act 2009. As a result, Pay.UK’s operation of these payment systems is subject to macroprudential regulation by the BoE-FMID.
We are based in the United Kingdom, operating in sterling only transactions and, as of 31 December 2021, we had 312 employees (consisting of permanent and fixed term contract colleagues). During the period, our Board was advised by two independent Councils: the End User Advisory Council and Participant Advisory Council; these councils work on behalf of end user and customer communities in the UK, ensuring that we remain true to our responsibilities and discharge our objectives effectively.
Our subsidiaries (all listed below) are also based in the United Kingdom.
- Bacs Payment Schemes Limited
- Cheque and Credit Clearing Company Limited
- UK Payments Administration Limited
- Faster Payment Schemes Limited (its subsidiary companies are listed below):
- Universal Trust Service Providers Limited
- Mobile Payments Service Company Limited
Pay.UK is committed to making sure that there is no modern slavery or human trafficking in our supply chains or any part of our business. Pay.UK understands slavery and human trafficking is an abhorrent abuse of human rights, and we continue to work towards the improvement of our systems and controls to detect, prevent and monitor this. Pay.UK acts ethically and with integrity in all our business relationships and we expect the same standards from all our contractors, suppliers and other business partners.
Pay.UK understands the risks our organisation could be exposed to, including slavery and human trafficking. We are guided by the government guidance “Transparency in Supply Chains etc. A practical guide” on how to mitigate against the risk of modern slavery and human trafficking taking place within our organisation or in any of our supply chains. Risks associated with modern slavery is reported to Pay.UK Risk Committee and escalated to the Pay.UK Board.
Our Colleagues play a vital role in maintaining robust and resilient payment services, encouraging innovation within retail payments and supporting the wider retail payments ecosystem. Our Ethical Code of Conduct represents our commitment to how we work and conduct ourselves and underpins all our policies.
We are committed to:
- maintaining trust in the certainty, integrity and security of our services and interactions with all clients, end-users, regulators, stakeholders and our colleagues;
- nurturing our people to drive industry innovation, creating relevant, competitive, useful and end-user focused payment solutions; and
- attracting, developing and retaining talented leaders and colleagues who, in line with our culture, principles and values can deliver excellence.
To enable a vibrant UK economy and deliver best in class payment infrastructure and standards, we continue to emphasise our core Values and hold our colleagues to account for these:
- We are Transparent
- We are Inclusive
- We are Respectful
- We are Curious
- We give Constructive Challenge
Our core Values embody Pay.UK ethos and, together with our policies and vision, set the tone for how we operate. We do not tolerate unlawful discrimination, bullying, or harassment on any grounds, including age, race, ethnic or national origin, colour, mental or physical health conditions, disability, pregnancy, gender, gender expression, gender identity, sexual orientation, marital status or other domestic circumstances, employment status, working hours or other flexible working arrangements, religion or belief. In 2021, we rolled out our Diversity & Inclusion (D&I) strategy, and have now expanded this to set up a new D&I Committee, which represents all areas across the business.
Pay.UK performs pre-employment screening on all colleagues, which includes verification of identity & UK right to work checks. These checks are also underpinned by our Immigration Framework which supports our recruitment and onboarding processes and procedures. We also conduct enhanced vetting on senior colleagues whose roles have greater accountability and responsibility.
Our continued commitment
Policies in relation to slavery and human trafficking
Our internal policies are essential for the organisation and form part of the core internal controls we use to manage our day-to-day business. The policies and associated procedures cover a number of key areas such as, Anti-Slavery & Human Trafficking Policy, Whistleblowing Policy, Recruitment and Onboarding Policy, Anti-Bribery and Corruption Policy and our Ethical Code of Conduct which underpins all our policies. We require all colleagues to understand and actively comply with our policies. In 2021, we also introduced an Immigration Framework which supports our comprehensive recruitment and onboarding processes and procedures.
We continue to apply our Equal Opportunities Policy at all stages of our recruitment and selection process. We shortlist, interview and select candidates with no regard to gender, gender reassignment, sexual orientation, marital or civil partnership status, colour, race, nationality, ethnic or national origins, religion or belief, age, pregnancy or maternity leave or trade union membership. Once appointed we remunerate our colleagues appropriately in accordance with industry standards.
Due diligence and risk management
We have a Third-Party Management Framework which we use to guide how we manage our suppliers. This Framework covers the full lifecycle of a relationship from sourcing, throughout commercial management, to exit management. When we onboard our suppliers, we conduct due diligence for business critical and high-risk suppliers using a third party called Creditsafe. The checks include adverse news screening, sanctions & enforcement screening, state-owned enterprise screening and politically exposed persons (PEPs) screening. Additionally, during the due diligence process we request a copy of our suppliers Modern Slavery Statement in order to review what they have done to prevent modern slavery in their business and supply chains.
As per our last statement we have started and continue to make notable enhancements to the Pay.UK Enterprise Risk Management Framework (ERMF). Our ERMF sets out our risk management process, tools and methodology that make sure that our legal and regulatory obligations are risk assessed, monitored, reviewed, reported and acted on accordingly. The risk appetite statements continue to be an integral part of our ERMF and set out our risk appetite to our legal and regulatory obligations.
Our suppliers range from accountancy firms, law firms, marketing agencies, large consultancies, recruitment agencies, personal service companies, IT system and hardware providers. The majority of our suppliers are based in the UK. Our analysis of our suppliers and the third-party independent assessment have determined the potential risk exposure of Modern Slavery within our business supply as low.
We continue to require all our suppliers and sub-contractors to comply with the law, and these are articulated within our contract terms. In addition, we expect our suppliers to implement steps within their own organisations that assist in combatting modern slavery within their businesses and supply chains.
Our customers are organisations that directly or indirectly buy or use our payments platform to deliver services to end users, and consist of Payment System Providers (PSPs) authorised by the Financial Conduct Authority (FCA) and/or the Prudential Regulation Authority (PRA), and include banks and non-bank PSPs, such as authorised e-money institutions. As part of the onboarding process, customers are expected to meet requirements placed upon them by their regulator/s and by the Bank of England.
We recognise that our customers who use our payment systems, have the potential to be indirectly/inadvertently involved with those who seek to exploit their services in respect of modern slavery and human trafficking. We expect most of our customers to have processes and procedures to combat/mitigate these risks as required by their regulators.
In accordance with our participation agreements, customers of Pay.UK systems are expected to comply with UK law and regulations. This includes meeting the requirements of s.54 of the Modern Slavery Act (publication of their Modern Slavery statement) and implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within their business or in any of their supply chains.
Training and Awareness
All colleagues at Pay.UK are required to complete mandatory training when they join and must also complete annual refresher training for some of our more high-risk areas such as Fraud and Bribery. We are continually enhancing our internal training for all colleagues to supplement trainings around key areas, such as:
- Modern Slavery Training,
- Bribery Prevention training,
- Fraud Prevention training.
Our Progress in 2021
Despite COVID-19, we have continued with our business operations which include addressing the potential risk of slavery and human trafficking within our business and our supply chain.
During 2021, the key enhancements that we made specific to risk of slavery and human trafficking were:
- Compliance Risk Assessment
We partnered with an external organisation to conduct a compliance risk assessment exploring our exposure to Modern Slavery within our business, supply chain and with our customers. This involved reviewing our policies, processes, and procedures in relation to Modern Slavery, outsourcing arrangements and the assessment of our Modern Slavery risk exposure. The review determined that Pay.UK’s residual risk to potential non-compliance with the requirements of Modern Slavery is low. This is mostly due to our industry, sector and type of procurement we undertake.
- Whistleblowing Policy and ‘Ethics Helpline’
In 2021, we continued to develop and update our Whistleblowing Policy and procedures to inform and support colleagues in raising concerns about any wrong doing, unethical, illegal or irresponsible activity at work without any fear of reprisals or retaliation. As part of the enhancements, we engaged with an external provider, Safecall, which provides a confidential resource for whistle-blowers to submit reports anonymously.
- Supplier Management
In 2021, we continued to develop and implement our Third-Party Management Framework to enhance our supplier management process. We implemented controls for the management of our current and new suppliers. Furthermore, we rolled out due diligence checks during onboarding and on a real-time basis for business critical and high-risk suppliers.
Our future plans
We are committed to continually strengthening our policies, processes and procedures where exposure to Modern Slavery risks may be higher and embedding these within our business and supply chain. Our Executive management team and Board have approved the following plans in respect of mitigating the risk of modern slavery and human trafficking:
- Launching and Promoting the ‘Ethics Helpline’
In 2022, we will be launching and promoting the ‘Ethics Helpline’ across the business to help raise awareness and encourage colleagues to use the service, anonymously if they wish to, as a confidential resource to report concerns or seek guidance about possible breaches of the law or our policies.
- Supplier Management and development of our Third-Party Management Framework
We continue to develop, implement and embed our supplier management framework, processes and procedures.
- ‘Active Bystander’ training and ‘Speak Up, Speak Out’ campaign
In 2022, we intend to launch ‘Active Bystander’, which is an innovative training to help us create a safe-to-speak culture. The training will teach colleagues the skills to identify, call out and challenge behaviours that do not align with our core Values, including behaviours that can be identified with Modern Slavery. The ‘Speak Up, Speak Out’ communication channel will provide a route to flag any concerns or grievances that don’t fall within our Whistleblowing Policy or procedures.
This Statement has been considered by the Executive Committee before approval by the Board of Directors.
On behalf of the Board of Directors of Pay.UK Group.
Chair, Pay.UK Limited