Slavery Statement

1. Introduction

Paynetics AD (‘Paynetics’, ‘we’, ‘our’, the ‘Company’) is an Electronic Money Institution authorised in Bulgaria (Decision #44 of 11 April 2016 of the Bulgarian National Bank), which provides payments services across the EU Member states on the grounds of passportisation of its licence and which operates under Temporary Permissions Regime in the UK (‘TPR’ firm 12481335).

2. Statement

Modern slavery is a crime and a gross violation of fundamental rights that can take different forms. Irrespective of what form it may take, it results in the deprivation of a person’s liberty by another, for the purpose of exploitation for personal or commercial gain.

Paynetics is dedicated in delivering a global service that has zero tolerance towards modern slavery and human trafficking within the Company’s own business areas as well as our supply chains.

We are committed to preventing acts of modern slavery and human trafficking from occurring within our business and/or supply chain, and imposes the same high standards on its suppliers. We work closely and maintain relationships with many suppliers and organisations and we are dedicated to having procedures in place that will manage and eliminate any risk of slavery and human trafficking.

This statement outlines the measures implemented by the Company to ensure that the requirements set out in the Modern Slavery Act of 2015 (‘MSA 2015’) are met and upheld by the internal structure of Paynetics as well as any of the commercial organizations within our supply chain.

3. Our Policies, Training and Conduct

At Paynetics, we are committed to conducting our business in line with our ethics and values, with the highest level of integrity.

Paynetics has a comprehensive internal framework for identifying and mitigating risks linked to our businesses and activities. This includes, but it is not limited to, a number of systems, controls and robust procedures for detecting and preventing unusual or suspicious behaviour, which could be, inter alia, connected to modern slavery and human trafficking.

Furthermore, Paynetics maintains a high standard of control and oversight, putting in place risk checks, and reports on unusual or suspicious activity to signal for cases for further inspection; strict precautions are kept ensuring that such alerts are always inspected.

We invest in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees are encouraged to identify and report any potential breaches of the organisations anti-slavery and human trafficking policy.

In addition, Paynetics has policies and procedures in place to encourage employees to report any suspicions and to raise any concerns including within our own organization and supply chain, without the fear of any retribution.

4. Due Diligence Process for Modern Slavery and Human Trafficking and Supplier Adherence

Paynetics strives to hold a high level of integrity and honesty throughout all the business relationships we engages in, so that everyone in the supply chain complies with the guidelines and ethical values of the Company. Contractors, and suppliers authorised to do business with Paynetics are expected to adhere to all the applicable laws, regulations, and requirements aligned against any financing achieved from modern slavery or human trafficking and that includes the MSA 2015.

As part of our efforts to monitor and reduce the risk of modern slavery and human trafficking occurring within our supply chains, we have adopted a risk-based-approach to assessing our suppliers and their adherence to our requirements, policies and procedures. Our approach is designed to:

Establish and assess areas of potential risk in our business and supply chains
Monitor potential risk areas in our business and supply chains
Reduce the risk of slavery and human trafficking occurring in our business and supply chains
Provide adequate protection for whistle-blowers
We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find evidence of a failure to comply with our approach to modern slavery and human trafficking we will immediately seek to terminate our relationship with the relevant supplier.

To prevent risks related to modern slavery and human trafficking Paynetics has taken an initiative to exercise periodic assessment of the due diligence procedures and ethical guidelines implemented by the Company to ensure that they are kept up to date with the corresponding industry standard.

5. BoardApproval

This statement is construed in compliance with Article 54 of the MSA 2015 and shall be amended on an annual basis following the approval of Paynetics Board of Directors to have an updated source of information.

This statement was approved by the Board of Directors of Paynetics AD on 27 October 2022.

Antonina Martinova