Modern Slavery and Human Trafficking Transparency Statement

Overview

This statement applies to Cepta, a trading name for Cepta Payment Services Limited. Below outlines Cepta’s approach to addressing the potential risk of modern slavery and human trafficking within its supply chains or any parts of its business. Cepta views modern slavery and human trafficking as unacceptable and abhorrent and is committed to implementing and enforcing effective procedures and controls to prevent these risks from infiltrating its business operations. Acting ethically and with integrity across all business activities and relationships is at the core of Cepta’s values.

Cepta’s purpose is to help businesses grow sustainably.

Cepta remains committed to operating in accordance with the International Bill of Human Rights and also takes into account the UN Guiding Principles on Business and Human Rights (UNGPs).

Cepta is regulated in the UK with the Financial Conduct Authority (FCA) in the UK and in Canada by the The Financial Consumer Agency of Canada (FCAC)

About Us

Cepta has policies in place that restrict or prohibit certain industries, several of which are at higher risk of human rights issues. For merchants operating in higher-risk sectors such as dating services, Cepta undertakes 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, Cepta has a policy not to process for any adult content services.

Cepta continually evolves its practices relating to underwriting, risk management, and onboarding, remaining cognizant of the modern slavery risks associated with the customer/merchant journey.

Customers/Merchants

Cepta has policies in place that restrict or prohibit certain industries, several of which are at higher risk of human rights issues. For merchants operating in higher-risk sectors such as dating services, Cepta undertakes 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, Cepta has a policy not to process for any adult content services.

Cepta continually evolves its practices relating to underwriting, risk management, and onboarding, remaining cognizant of the modern slavery risks associated with the customer/merchant journey.

Our Suppliers

Cepta’s suppliers are mainly based in the UK, Canada, US, Kenya, and Nigeria, with a focus on supporting its platforms.

Cepta’s supply chain is predominantly made up of:

• Hardware and software, including IT equipment

• Data storage services

• Professional services, including consultants and accounting firms

• Office equipment and facilities services

Although Cepta does not have a complex supply chain, due to the nature of its business model, it realizes that this could be an area of risk in terms of modern slavery and human trafficking. Cepta is therefore looking at what it can do to mitigate these risks in both the short, medium, and long term.

When taking forward requests for proposals (RFP) for new suppliers, Cepta undertakes due diligence to understand the environmental, social, and governance practices of the organization. This will make reference to relevant policies and procedures regarding human rights, labour standards, and modern slavery. An assessment of the responses will help Cepta gauge the risk level of modern slavery for these new suppliers.

Cepta will not knowingly support or do business with any organization that is, or could potentially be, involved in such practices.

Colleagues

Cepta’s recruitment process has measures in place to help prohibit instances of modern slavery within its workforce. Cepta undertakes 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 detailing their rights and responsibilities, including information on sick pay, annual leave, and other benefits. All staff are paid above the local minimum wage, and Cepta is 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 also provides details on relevant policies relating to employment. Cepta’s Dignity at Work policy provides information on the behaviours expected of colleagues to ensure all staff are treated respectfully and fairly. Cepta’s Whistleblowing policy, within its 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.

Future Actions

Cepta has a responsibility, as a global fintech, to continually make progress when managing the risks associated with modern slavery and human trafficking.

Cepta is looking into initiatives over the next year to help within this space. These include, but are not limited to:

• Introducing a centralized procurement function to provide greater oversight and full accountability of the Group’s sourcing activities.

• Implementing comprehensive policies and procedures around responsible sourcing with specific reference to modern slavery and human rights and the means to mitigate the associated risks.

• Issuing a Group-wide statement on Cepta’s approach to human rights across all its business activities.

• Launching a new risk monitoring system to enhance Cepta’s ability as an organization to monitor and mitigate risks of financial crime and suspicious behaviours.