Nov 18, 2022
This statement applies to Trust Payments Group Ltd, its companies and subsidiaries. The below sets out Trust Payment’s approach to dealing with the potential risk of modern slavery and human trafficking occurring within Trust Payment’s supply chains or any parts of its business. We view modern slavery and human trafficking as unacceptable and abhorrent, and we have a commitment to implementing and enforcing effective procedures and controls to prevent the risks of human trafficking and other modern slavery practices infiltrating our business operations. Acting ethically and with integrity across all our business activities and relationship is at the core of Trust Payments’ values.
Trust Payments’ purpose is to help businesses grow sustainably.
We remain committed to operating in accordance with the International Bill of Human Rights and also take into account the UN Guiding Principles on Business and Human Rights (UNGPs).
We are regulated in the UK and the EU through our group companies: (1) TrustUK Payments Limited with the Financial Conduct Authority in the UK and (2) Trust Payments (Malta) Limited with the Malta Financial Services Authority in Malta.
We have policies in place that restrict or prohibit certain industries, several of which are at a higher risk of human rights issues. For our merchants operating in higher risk sectors such as dating services, we undertake enhanced due diligence to flag adverse media or non-compliance with rules and regulations that could include human rights or modern slavery issues. Please note, we have a policy not to process for any adult content services.
We continually look to evolve our practices relating to underwriting, risk management and onboarding and remain cognisant of the modern slavery risks associated with the customer/merchant journey.
We have policies in place that restrict or prohibit certain industries, several of which are at a higher risk of human rights issues. For our merchants operating in higher risk sectors such as dating services, we undertake enhanced due diligence to flag adverse media or non-compliance with rules and regulations that could include human rights or modern slavery issues. Please note, we have a policy not to process for any adult content services.
We continually look to evolve our practices relating to underwriting, risk management and onboarding and remain cognisant of the modern slavery risks associated with the customer/merchant journey.
Our suppliers are mainly based in the UK, EU and the US with a focus on supporting our platforms.
Our supply chain is predominantly made up of:
Although we do not have a complex supply chain, due to the nature of our business model, we realise that this could be an area of risk in terms of modern slavery and human trafficking. We are therefore looking at what we can do to mitigate these risks in both the short, medium and long term.
When taking forward requests for proposals (RFP) for new suppliers we undertake due diligence to understand the environmental, social and governance practices of the organisation. This will make reference to relevant policies and procedures regarding human rights, labour standards and modern slavery. An assessment of the responses will help us to gauge the risk level of modern slavery for these new suppliers.
We will not knowingly support or do business with any organisation that is, or could potentially be, involved in such practices.
Our recruitment process has measures in place to help prohibit instances of modern slavery within our workforce. We undertake background checks on new colleagues to ensure eligibility for their role and the relevant rights to work in their country of employment.
Employment contracts and an Employee Handbook are provided to each employee which detail their rights and responsibilities including information on sick pay, annual leave and other benefits. All staff are paid above the local minimum wage and we are working towards becoming a Living Wage accredited employer in the UK.
All new hires and current staff will undertake mandatory training on modern slavery and human trafficking, economic crime, conduct risk and anti-money laundering in 2023. Specialist teams, such as the risk and compliance teams and the customer service team, undertake additional training including on customer due diligence, complying with sanctions and fighting fraud. Training is compulsory and completion rates are monitored.
The Employee Handbook will also provide details on relevant policies relating to their employment. Our Dignity at Work policy provides information on the behaviours expected of our colleagues to ensure all staff are treated respectfully and fairly. Our Whistleblowing policy, within our Employee Handbook, is in place to enable employees to raise concerns internally of malpractice, impropriety or unethical behaviour including any suspected instances of modern slavery.
We have a responsibility, as a global fintech, to continually make progress when managing the risks associated with modern slavery and human trafficking.
We are looking into initiatives over the next year to help us within this space. These include, but are not limited to:
Daniel Holden,
Chief Executive Officer
Security is our top priority at Trust Payments and we strive to ensure that all data is kept secure at all times We keep all customer data safe with AES256 encryption, SSL Certificates, and a minimum of TLS1.2, between your website and our datacentres.
Our systems are scanned quarterly using the Qualys PCI Platform, an independent Qualified Security Assessor (QSA) and approved vendors – Omnicybersecurity (UK) & Forgenix (US) – to ensure compliance with the security requirements of the card schemes.
We follow a number of rigorous security procedures on a daily basis including, but not limited to, continuous monitoring of our perimeter, dark web monitoring, and internal checks to ensure that CIA triad is maintained at all times.
