Modern Slavery Statement
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 our business.
We have a zero-tolerance approach to Modern Slavery.
Pay.UK is committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our business or in any of our supply chains.
This is the third 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 2020. 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.
Pay.UK acknowledges the UK government’s new measures, (announced on 22 September 2020), for tackling modern slavery within organisations supply chains, in particular the single reporting deadline of 30 September, and the commitment to establishing a single enforcement body.
Our organisation and structure
Pay.UK Limited and its subsidiaries (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 2020, we had 265 employees (consisting of permanent and fixed term contract colleagues). Our Board is advised by two independent Councils: the End User Advisory Council and Participant Advisory Council; these councils work on behalf of end user and Participants (our equivalent of customers) 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
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 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 that slavery and human trafficking is taking place within our organisation or in any of our supply chains. Risk associated with modern slavery is reported to Pay.UK Risk Committee and escalated to the Pay.UK Board.
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 and/or prevent this. We expect similar standards from all our contractors, suppliers and other business partners.
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.
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:
- Working well together
- Empowering people
- Championing end user outcomes
- Acting with integrity and professionalism
- Innovating through challenge
Our 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, or religion or belief.
In 2020, Pay.UK embarked on its journey to developing its Diversity and Inclusion strategy sponsored by the interim CEO and supported by the Board, which will ensure that we have further processes that support the battle against modern slavery and human trafficking.
Our Progress in 2020
The Impact of the Coronavirus Pandemic (Covid-19)
Covid-19 created challenges across the world which resulted in tragic, global loss of life, and economic disruption. As with many other organisations we had to change the way we work and adapt our operating model to one which prioritised the safety of our colleagues. The health and safety of our colleagues is of paramount importance to Pay.UK and we concentrated our efforts in 2020 on providing mental and physical support through challenging and unprecedented times.
Despite COVID-19, we have continued with our business operations which includes addressing the potential risk of slavery and human trafficking within our business and our supply chain.
During 2020, the key enhancements that we made specific to risk of slavery and human trafficking were:
- Enhanced compliance risk assessment
|We sought to complete an enhanced qualitative compliance risk assessment, exploring potential exposure within our supply chain and also with our Participants. In 2020, we partnered with an external organisation to conduct an additional assessment on our potential exposures, which included reviewing our processes, procedures, outsourcing arrangements and the assessment of modern slavery risk exposure. We believe our exposure is low, due to of our industry, sector and type of procurement we undertake. The assessment is scheduled for completion in Q2 2021.|
- Policy suite review and whistleblowing champions
|We developed a Policy Framework and Procedure to inform and support our Colleagues in the management of policies. As part of this process we are reviewing and making enhancements to our overall policy suite, by embedding controls and developing a supported evidence-based policy effectiveness monitoring programme. In addition, we appointed whistleblowing champions in line with Financial Conduct Authority (FCA) guidance.|
- Supplier Management
|We continue to develop our control frameworks to enhance our supplier management process. In 2020, we commenced the implementation of the supplier management framework that will continue to support and embed controls for the management of our current and new suppliers.|
Our future plans
Our Executive management team and Board have approved the following plans in respect of mitigating against the risk of modern slavery and human trafficking:
- 2020 compliance risk assessment recommendations
|We will be realising any relevant recommendations from the independent third-party compliance risk assessment completing in 2021.|
- Risk-based compliance training
|We are developing a risk-based compliance training programme, across all our legal obligations, which will enable us to work closely with colleagues within departments such as procurement and human resources, where the exposure to modern slavery risk may be higher.|
- Supplier Management
|We continue to develop our supplier management framework, processes and procedures.|
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, Modern Slavery, Whistleblowing, Recruitment and Onboarding and Anti-Bribery and Corruption. We require all colleagues to understand and comply with our policies.
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
In 2020, we continued to develop the frameworks that support us with supplier management. In addition, we focused on enhancing controls with regards to how we onboard our suppliers. We enhanced our process and offered training to staff in relation to screening and reviewing new suppliers.
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 which ensures 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. These are continuously reviewed and approved annually.
Our suppliers range from banks, accountancy firms, law firms, large consultancies, recruitment agencies, personal service companies and IT system and hardware providers. Our analysis and the third-party independent assessment have determined the potential risk exposure of Modern Slavery within our business supply is 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.
Participants of Pay.UK systems 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. UK participants are essentially customers to our services. As part of the onboarding process Participants are expected to meet requirements placed upon them by their regulator/s and by the Bank of England.
We recognise that our Participants, 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 our participants to have processes and procedures to combat/mitigate these risks as required by their regulators.
In accordance with our participation agreements, participants of Pay.UK systems are expected to comply with UK law and regulations. This includes meeting the requirement 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
As highlighted above we are enhancing our internal training to augment our current training around key areas such as areas of law such as Bribery Prevention, Fraud and Modern Slavery.
This Statement has been considered by the Executive Committee before approval by the Board of Directors on 12 May 2021.
This Statement is signed by the Chairman on behalf of the Board of Directors of Pay.UK Group.