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 31st of December 2022.
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 statement has been approved by the PXP Board Members and is in relation to PXP and its business.
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;
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.
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:
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.
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.
In addition to that, any supply agreements made on the supplier’s terms are duly reviewed by our Legal teams to ensure that the supplier is obliged to comply with Modern Slavery Act 2015 and/or any similar applicable legislation within the relevant territory.
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. At PXP we use the following key performance indicators (KPIs) to better understand the effectiveness of our approach to managing modern slavery risks:
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.
Version 1.0 of January 2023.