Modern Slavery Statement
The UK Modern Slavery Act 2015 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.
Pay.UK publishes this statement in accordance with section 54(1) of the Modern Slavery Act 2015
(the Act). Our statement sets out the steps that we are taking to help to prevent, and detect any incidents of Modern Slavery occurring in our business and applies to the Pay.UK financial year ending 31 December 2019.
Our organisation and structure
Pay.UK Limited and its subsidiaries (Pay.UK Group) are regulated by the Bank of England (Financial Markets Infrastructure Directorate) and the Payment Systems Regulator. We are based in the United Kingdom, operating in sterling only transactions and, as of 31 December 2019, we had 223 permanent employees. Our Board is advised by two independent advisory councils. These councils work on behalf of end user and participants (our customers) communities in the UK, ensuring that we remain true to our responsibilities and discharge our objectives effectively.
Our subsidiaries are also all based in the United Kingdom.
As the systemic risk manager for the payment systems we operate, understanding the risks our organisation could be exposed to, including Modern Slavery and human trafficking are extremely important considerations for our business and our supply chains. Pay.UK is committed to continuous implementation and improvement of systems and controls, to ensure Modern Slavery is not taking place anywhere in our organisation or in any of our supply chains. We expect similar standards from all of our contractors, suppliers and other business partners.
Pay.UK impacts almost every person and every business across the UK. 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. To enable a vibrant UK economy and deliver best in class payment infrastructure and standards, we have a set of core values and hold our colleagues to account for these. These values embody Pay.UK’s ethos and, together with our policies and vision, set the tone for how we operate.
- Working well together
- Empowering people
- Championing end user outcomes
- Acting with integrity and professionalism
- Innovating through challenge
Our internal policies are essential for the organisation and form part of the internal controls we use to manage our day-to-day business. We require all colleagues to understand and comply with our policies, embedding our legal, regulatory and ethical commitments. We also share these with our business partners.
Anti-Slavery and Human Trafficking Policy
Our policy in relation to Modern Slavery explains Pay.UK zero-tolerance approach to Modern Slavery and human trafficking, and our commitment to conducting our business ethically, and transparently. We encourage openness and are committed to supporting anyone that raises concerns – embedded in our Whistle Blowing and Grievance Policies.
Employment policies and practices
As an employer we are committed to our people, and have developed policies, processes and procedures aligned to employment practices including the Equality Act. Our Ethical Code of Conduct Policy explains our ways of working and the standard of behaviour we expect from our colleagues, our partners and our suppliers.
Recruitment process and screening
We are committed to applying our Equal Opportunities Policy at all stages of our recruitment and selection process. Shortlisting, interviewing and selection is be carried out without 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.
As part of our recruitment process we conduct background checks to:
- Reduce the risk of recruiting colleagues who may present a risk to the business
- Minimise the likelihood of existing colleagues becoming a potential risk
- Minimise the risk of Modern Slavery or human trafficking
Our Screening and Security Policy applies to all our colleagues which include permanent, fixed-term and temporary employees, and those that perform a service for Pay.UK (such as contractors, agencies, and secondees).
Our suppliers range from banks, accountancy firms, law firms, large consultancies, recruitment agencies, personal service companies and IT system and hardware providers. Our analysis has determined the potential risk exposure of Modern Slavery within our business as low.
We believe it’s important for our suppliers to share a similar commitment to combatting Modern Slavery and upholding human rights. It is our expectation that all our suppliers and sub-contractors comply with the law and implement steps within their own organisations that assist in combatting Modern Slavery within their businesses and supply chains.
As part of our wider organisation maturity plans we are developing frameworks to enhance our supplier management process and better understand our wider supply chain.
Training and awareness
Our senior management team approve our annual colleague training and awareness programme. Our plan covers specific areas of law such as Bribery Prevention, and Modern Slavery. In addition we have offered focused training to colleagues working in areas of the business that we have identified to be higher risk, for example our Procurement team.
Our future plans
We continue to review our processes and procedures in order to help us detect, prevent and respond to the potential risk of Modern Slavery and human trafficking within our business and our supply chain. We have already started to make notable enhancements to the Pay.UK Enterprise Risk Management Framework. One key enhancement is the Board approval of a new set of Risk Appetite Statements, with one of those statements focusing on Legal and Regulatory responsibilities. We continue to progress with these enhancements including developing the systemic risk management of the payments ecosystem, due diligence processes, management of our suppliers and the on-boarding of our suppliers.
The coronavirus pandemic has created challenges across the world. During these challenging times we continue to focus on the health and safety of our colleagues. As a result we changed the way we usually work and operating model. The coronavirus pandemic impacted our ability to meet our Board meeting for the approval of our statement before 30 June 2020, which has resulted in a slight delay with the publication of this statement.
The Pay.UK board has approved this statement and we will review and update it on an annual basis.