Modern Slavery Act 2015

Voluntary slavery and human trafficking statement

We are committed to improving our practices to combat modern slavery in our business by taking steps, as far as we are able, to ensure that our supply chains are free from slavery and human trafficking. This statement sets out the steps we have taken in from 2024 to 2025 to understand potential modern slavery risks within our business structure and supply chain, and as well as the steps taken to eradicate these risks.

About us

We are a small to medium sized enterprise providing cloud-based secure payment card services, primarily in the call centre sector.

Our annual turnover is under £36 million. Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to identify risks and tackle modern slavery and human trafficking in our business and in our supply chains.

Our supply chains mainly consist of the following:

  • Amazon Web Services (AWS) (aws.amazon.com): provider of data centres and virtual infrastructure for the core PCI Pal applications;
  • Megaport (www.megaport.com): provision of SD WAN network to provide egress and ingress points to the PCI Pal AWS network;
  • Gamma Telecom Ltd (www.gamma.co.uk) : inbound and outbound PSTN connectivity services; and
  • Third party IT services providers underpinning the business operations of PCI Pal (Microsoft, Dropbox, Salesforce).

Policies and commitment to ethical trading

Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

We are committed to ethical trading principles and to acquiring goods and services without harm to others.

Due diligence and risk assessment

To help identify and monitor the risk of slavery and human trafficking in our supply chain we vet material suppliers and sub-contractors to ensure that they are committed to ethical labour practices. We include provisions which ensure compliance with anti-slavery and human tracking laws in all our contracts with suppliers. All suppliers are expected to observe the provisions of PCI Pal’s Code of Conduct, available here: https://legal.pcipal.com/suppliercodeofconduct.html

Effectiveness in combating slavery and human trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • The percentage of suppliers and sub-contractors vetted for ethical labour practices.
  • The number of reported breaches in the past year.

There were no reported breaches in the past year.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we ensure that our staff are aware of their obligations related to combating slavery and human trafficking both within the organisation and throughout our supply chain. Only directors and senior managers are authorised to hire personnel and/or procure goods and services from reputable entities.

Modern Slavery Act Signature

Adrienne Brophy
PCI Pal
General Counsel