MODERN SLAVERY STATEMENT

About this Statement

The Modern Slavery Act 2015 (the Act) requires certain businesses to publish an annual 'Morden Slavery Statement' which sets out the steps taken during the previous financial year to ensure that slavery or human trafficking is not taking place in its business or supply chain.

This statement is made in accordance with section 54 of the Act and applies to PXP Financial Limited (PXP) and its subsidiaries for the financial year ending on the 31^st of December 2023.

PXP is committed to ensuring that our business has no involvement in modern slavery or human trafficking and has taken steps to ensure that human trafficking, slavery, servitude and forced or compulsory labour is not taking place in our supply chains or in any part of our business.

As is a leading payments provider, PXP has a zero-tolerance approach towards modern slavery will not support or deal with any business knowingly involved in modern slavery or human trafficking.

We recognise the inherent risk we face by simply operating our business and working with third party suppliers. We also recognise we have an important role to play in identifying customers and its clients who may be victims or perpetrators of modern slavery. Through this statement, we have detailed our controls and practices to combat this serious crime.

PXP has many years of experience in the world of payments. Today, we have around 200 employees from 25 nationalities working across offices in various locations. PXP is an equal opportunities employer that embraces diversity and inclusivity.

PXP is fully committed to acting with integrity at all times and to treat everyone with dignity and respect. We are continuously improving effective controls to ensure that modern slavery and human trafficking have no place in our business at any level.

This is our second Modern Slavery Statement, it has been reviewed and approved by the PXP Board Members and is in relation to PXP and its business.

 

Our organisation structure, customers and supply chains

PXP Financial Limited is a private company, incorporated in England and Wales. It is the holding company for all its subsidiaries. The Board Members have oversight of PXP’s approach to combatting modern slavery through the annual review and approval of our statement.

Our business largely uses professionally qualified people employed directly by PXP and its subsidiaries. For us it is very important to ensure a fair treatment of our people in all our locations.

Our suppliers are mainly those providing technological or marketing support to us, located predominantly in the UK and EU; therefore the majority of our direct suppliers are based in jurisdictions which are low risk for modern slavery, according to the Global Slavery Index. Our small number of suppliers outside of the UK and EU are large firms which have undergone rigorous due diligence and are managed by dedicated PXP managers.

Our suppliers are required to take steps to prevent modern slavery and human trafficking in their own businesses and supply chains, whether under the Modern Slavery Act 2015 or equivalent legislation in other jurisdictions. We do not tolerate modern slavery throughout our supply chain and are committed to work with our third parties to eradicate and mitigate modern slavery.

Our customers are merchants and partners mainly established in the following sectors;

• Retail
  
  
• Hospitality & Entertainment
  
  
• Cruise & Travel and
  
  
• Gaming.

We’re committed to combatting financial crime, including modern slavery, as it relates to our merchants and its clients. Modern slavery is a crime and any benefits people get from those actions are the proceeds of crime. PXP is committed to fighting any type of financial crime, including modern slavery.

We have a Risk Procedure for Ongoing Merchant Transaction Monitoring Policy which sets out the principles and requirements for creating a company-wide anti-financial crime culture to detect, deter and, where possible, prevent financial crime. This Policy is reviewed and approved by the Head of Risk and Fraud Management on an annual basis.

Our commitment in relation to anti-slavery and human trafficking

PXP has committed itself to a zero-tolerance position on violations to the UK’s anti-human trafficking and anti-modern slavery laws.

Our main principles are based upon respect and appreciation, treating everyone fairly and consistently, creating a business environment that is open, transparent and trusted, which embody everything that we do at PXP and how we do our business.

Our policies and procedures relating to the Modern Slavery Act are in line with our culture and values. Our specific procedures to address modern slavery risk include:

• PXP Financial Group Code of Conduct & Ethics.
  
  The PXP Financial Group’s Board requires the highest possible standards of professional and ethical conduct of itself and from all employees. This Code of Conduct and Ethics sets out the basic ethical standards which are required across the PXP group, and reflects our commitment to conduct all our business in an honest and ethical manner.
  
  
• Due diligence processes, risk assessment and management.
  
  When we engage with new customers or suppliers this includes an initial due diligence in accordance with the implied risk areas to ensure that the company has a good reputation with appropriate practices in several areas including people and culture. A procedure for Customer & Supplier Due Diligence within PXP is detailed below.
  
  
• Risk Assessment.
  
  PXP conducts regular assessments of its operations and supply chains to identify any particular sectors or geographies where a greater risk of modern slavery or human trafficking may occur and have sought to identify what measures are in place to mitigate those risks.
  
  

How we combat the risks of modern slavery in our business environment

1. All staff of PXP are employed in accordance with all aspects of current employment legislation in the countries in which we operate.
   
   
2. PXP is committed to raising awareness about modern slavery throughout the business to ensure that staff are equipped to respond to the changing nature of this hidden crime.
   
   
3. All our staff receive training, which is mandatory for all UK colleagues, to support them in understanding the risks of human trafficking, slavery, servitude and forced or compulsory labour and to encourage them to notify their line manager and the Compliance team via compliance@pxpfinancial.com if they believe or suspect that a conflict with our Modern Slavery Statement has occurred (or may occur in the future).
   
   
4. All our new contractors and suppliers are monitored under all applicable anti-slavery and human trafficking laws, statutes and regulations, and have a contractual obligation to comply with all applicable laws that apply to their supply of goods and services to us, regardless of the jurisdiction in which they operate.
   
   
5. PXP takes responsibility for this Statement and its related objectives and will review and update it in accordance with The Act, at least on an annual base.
   
   

Procedure for Customer & Supplier Due Diligence within PXP

When conducting due diligence on potential suppliers for major projects, PXP require them to complete a Supplier Due Diligence Questionnaire which includes a requirement for the supplier to confirm upfront as part of their proposal that they are familiar with and shall comply with the Modern Slavery Act 2015 and/or any similar applicable legislation within the relevant territory.

Compliance team review and assess the completed questionnaire and advise if a supplier meet any of the good practice in relation to modern slavery policies or if it is being at of any risk.

All questionnaires completed in 2023 have been reviewed by assessed by PXP Compliance team. They all considered to be adequate with no signs of high risk in relation to Modern Slavery or non-compliance with the UK Modern Slavery Act.

We accepted the fact that an assessment cannot not always be positive. If a supplier is identified as a high risk, or non-compliance with the UK Modern Slavery Act, dedicated PXP manager are required to investigate and manage through to resolution.

Where a supplier fails to develop an improvement plan or the issue is deemed sufficiently serious or cannot be resolved in a reasonable time frame, PXP may take a decision do not enter into contractual relationship or undertake a review of the terms of the contract, which could include triggering the right to terminate.

 

Measuring Effectiveness

PXP recognises that review and assessment of actions to identify and address modern slavery risks across the business and supply chain will be an ongoing and evolving process.

This year we have improved key performance indicators (KPIs) for even better understanding of the effectiveness of our approach to managing modern slavery risks.

In 2023 we applied tailored approach and measure the Modern Slavery Trainings success rate across relevant employees, to whom we assign Modern Slavery Trainings.

• The proportion of PXP staff successfully trained in relation to modern slavery and trafficking - 2023 KPI results - 100%.
  
  
• Number of reports of modern slavery through our Compliance team via compliance@pxpfinancial.com - 0.

We continue to assess KPIs to improve existent or develop future metrics to measure the effectiveness of our actions, and enhance our monitoring over time.

We recognise that modern slavery and human rights breaches can be difficult to detect and we remain committed to monitoring and, where necessary, improving our processes to ensure any occurrences of human rights breaches, modern slavery and trafficking are detected.

Whilst intelligence available on modern slavery and human trafficking is limited, PXP regularly engages with intelligence providers such as law enforcement, charities and other organisations working to counter such risks.

 

PXP Modern Slavery Statement - 2023