Modern Slavery & Human Trafficking Statement
EVO Payments International Group
Modern Slavery & Human Trafficking Statement
We strive to ensure that modern slavery or human trafficking does not exist within our supply chain or our businesses. This objective is implicit in our policies and our approach to human rights.
This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 with respect to the financial year ending 31 December 2018 and sets out the approach EVO Payments International Group has in place to prevent the occurrence of modern slavery and human trafficking in our supply chain or in any of our business operations in the United Kingdom and elsewhere.
EVO Payments International Group is one of the fastest growing payment support business groups in the world. The Group provides a broad range of payment services, including acquiring, processing, ATM support and foreign currency conversion. All of these services are provided by the Group throughout North America and Europe with selected services being offered in the United Kingdom. In the United Kingdom the entities providing these services include EVO Payments International GmbH, Branch UK, a branch of a separately authorized and regulated payments institution, and EVO Payments International UK, Ltd., an unregulated corporate entity which provides group management and back office support.
You can find out more about the Group’s trading divisions in all jurisdictions, and a list of its products and services here.
The Group operates a number of policies which reflect our objective to acting ethically and in line with our legal and regulatory obligations with regard to our employees, customers and our business relationships.
The Group Code of Conduct (“Code”) is the standard that we set ourselves for what we say and do in our relationships with our customers, suppliers, colleagues, shareholders, regulators, government bodies and other parties. The Code represents our approach to the standards we expect from each other and it prescribes a set of behaviours expected of all employees of the EVO Payments International Group, wherever they work. We organise these standards under five categories with clear lines of individual responsibility:
Customers – we treat customers fairly;
Vendor/Suppliers – we carefully vet and monitor our supply partners and ask that they conduct themselves in a manner that reflects our standards;
Conduct – we act with integrity in our dealings;
Colleagues – we are respectful to each other and value the contribution of others;
Compliance – we comply with the Code, our policies and applicable legal and regulatory obligations.
The Group Whistleblowing Policy details the procedures our employees should follow if they have concerns about any wrongdoing, unlawful conduct, bribery, financial malpractice, dangers to the public or the environment, or possible fraud or other risks to the EVO Payments International Group.
The Group Recruitment Policy outlines our approach to recruiting employees for jurisdictions in which the EVO Payments International Group operates. The principles of equality underpin our resourcing activity, seeking to ensure that the recruitment and selection processes are designed to support fairness.
Group Anti-Bribery and Corruption Policy applies to all directors, officers and employees of the EVO Payments International Group, as well as third parties such as suppliers and sets out the rules with regard to bribery and corruption.
Group Anti-money Laundering Policy applies to all our employees and sets out policies and procedures to prevent the commission of financial crime and the movement of money which has derived from crime.
Group Third Party Vendor Policy sets out the requirements for the effective and consistent management for the procurement of Goods and Services for the Group while ensuring that consistent procurement best practices are followed across the Group.
Our Supply Chain
As the Group is not in an industry with a high risk of modern day slavery, a risk based approach has been adopted to review supply chains that fall within industries that carry a high risk of modern day slavery.
In conducting appropriate due diligence, the Group assesses its suppliers across a number of key risk areas, at the on-boarding stage and annually thereafter. The Group seeks assurances (where appropriate) from our suppliers that they are complying with applicable laws and regulations including laws relating to minimum wages, working conditions, overtime, child labour and applicable labour and environmental laws. This allows us to select suppliers to work with us who adhere to appropriate standards.
Detailed financial analysis and assessment of suppliers, reputations and experience is carried out. We also seek to identify if our suppliers operate a vendor management programme and carry out due diligence on their own suppliers to ensure that appropriate standards are being passed through the supply chain.
Our suppliers are required to notify us of a breach of applicable laws or regulations. We also monitor the content of modern slavery and human trafficking statements published by our suppliers.
Training and Awareness
EVO Payments International Group is focussed on raising awareness of the policies listed above with colleagues across the organisation. This includes the provision of mandatory training for employees on the Group Code of Conduct and Whistleblowing Policy each year.
Our managers also receive further support that includes training and line management guidance to ensure consistency of our recruitment processes, management of suppliers, fair treatment at work, and inclusion and diversity.
Boards of Directors Approval
Responsibility for ensuring that the Group has appropriate policies in place to meet our obligations under the Modern Slavery Act rests with the boards of the impacted group entities and this statement and the underlying policies cited herein are reviewed by said boards annually.