Slavery and trafficking policy

 

PCI Pal is committed to combating modern day slavery and human trafficking within its business and from within its supply chains, including sub-contractors, and partners.  This policy outlines our approach to identifying and preventing modern slavery without our operations and supply chains. 

 

The Company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. These, as well as the suppliers of services, make up the supply chain within PCI Pal. The company will not support or deal with any business knowingly involved in slavery, child labour or human trafficking.

 

We unequivocally condemn modern slavery and human trafficking in all its forms, including forced labor, child labor, and any form of exploitation. We are committed to upholding the principles of human rights and ethical labor practices throughout our business activities.

 

All employees are expected to adhere to this policy and report any concerns or suspicions of modern slavery/trafficking promptly.

 

 As part of the company’s due diligence processes into slavery and human trafficking the supplier approval process will incorporate a review of the controls undertaken by the supplier. PCI Pal is a software business and therefore does not purchase many physical supplies, and has very few supplies that originate outside the United Kingdom. However the company recognises that imported goods from sources from outside the UK and EU are potentially more at risk for slavery/human trafficking issues. The level of management control required for these sources will be continually monitored.

 

The senior management team shall take responsibility for implementing this policy statement and its objectives.  They will ensure their staff complete the modern slavery and trafficking training, and understand that all staff assess the ethical and legal compliance of our suppliers and contractors.  This may include evaluating their policies, practices and supply chain mechanisms to ensure they meet our standards for preventing modern slavery and trafficking.

 

Wherever we recruit contractor/agency staff a clear written agreement stating pay, working hours, holidays and other required legal provisions will be prepared and signed by PCI Pal and the employee.  All staff, including contractors/agency staff, undergo a thorough onboarding process to check eligibility to work.  All hiring is carried out via our reputable recruitment partners (which is kept to 2 - 3 suppliers), with clear contracts and fee structures in place.  Any placement fees are paid by PCI Pal, and not by the employee.  Placement fees are transparant and traceable, with charges being set out in invoices which are subject to our standard annual financial audit.

 

All employees undergo modern slavery and trafficking awareness training, delivered via our LMS (e-learning platform).  This training not only sets out PCI Pal's approach, but also highlights our role in maintaining awareness of instances of modern slavery outside of the business, and how to safely take action.

 

This policy takes into account and supports, the policies, procedures and requirements documented in our Integrated Management System, compliant with the requirements of quality security management system certified to ISO 27001 (Information Security Management Systems), ISO 9001 (Quality Management Systems), ISO 14001 (Environmental Management Systems) and ISO 22301 (Business Continuity Management Systems) standard or equivalent for all the Services. The implementation and operation of this management system underlines our commitment to this policy.

 

Non compliance of this policy by employees may result in disciplinary action (including termination of contracts) or legal consequences depending on the severity of the violation.

 

Employees are advised to report any instances (either confirmed or suspected) as soon as it is safe to do so.  This can be to the police using their usual emergency or reporting telephone numbers, or by reporting a concern using the following mechanisms:

 

In the UK:

 

In the US:

 

 

In Australia: