Modern Slavery Statement | CatalystPay

Modern Slavery Statement

[Latest update: Feb 01, 2021]


We oppose all forms of slavery which consists of but is not limited to: human trafficking, drug trafficking, sex trafficking, and unpaid labour. We make this statement to set out the steps we have taken to adhere to the requirements of the Modern Slavery Act 2015 and to reflect a drive to eradicate modern slavery in commercial organisations within our supply chain.


Policies on slavery, servitude, forced or compulsory labour, and human trafficking

We will conduct all business with integrity, having a zero-tolerance approach to modern slavery risks. Therefore, we are committed to working and operating by the International Bill of Human Rights (comprising the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights). We also take into account the UN Framework and Guiding Principles and other internationally accepted human rights standards.


Global Modern Slavery Policy

Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure that slavery (including human trafficking, drug trafficking, sex trafficking, and national minimum wage violations) is not taking place at any point across our supply chains.


Whistleblowing Policy

Our Whistleblowing Policy encourages employees to play a key role in preventing and detecting wrongdoings within the company. Employees are encouraged to raise their concerns about any suspected or known criminal conduct or any other type of misconduct taking place through the company, its customers or third parties. Employees can raise disclosures anonymously and confidentially.


Employment Policy

We treat all employees with dignity and respect to foster an environment that is free from discrimination, harassment and any form of bonded or forced labour. Our commitment to respecting human rights in the workplace is embedded within our values and employment policies and practices.

Our employees are made aware of their employment rights through a variety of channels including written employment contracts, employee handbooks, and internal communications. Employees receive training on core human rights-related issues, including but not limited to diversity and inclusion, money laundering, third-party risk management, and bribery and corruption.


Impact on our Supply Chains

Our supply chains are made up of the following:

  • IT services and communications including customer support activities
  • Financial institutions and payment processors
  • Security services


Third-Party Due Diligence

Catalystpay deals with a broad range of third parties, and it is our intention to only contract with third parties who can satisfy our standards with regards to employment and welfare conditions. To help  identify and monitor the risk of slavery and human trafficking in our supply chain we conduct due diligence on existing and new third parties taking into account three risk factors:

  • The country the third-party operates in (and has supply chains in);
  • The sector the third-party operates in; and
  • The products produced, manufactured or supplied by the third-party 

Catalystpay adopts a risk-based approach to address modern slavery risks. For high-risk third parties, Catalystpay requests the completion of modern slavery due diligence questionnaires. The basis for the risk-based approach applied to third parties derives from two sources:

  • The Global Slavery Index, and
  • The Global Estimates of Modern Slavery


The Global Slavery Index

The Global Slavery Index is a leading global indicator of modern slavery worldwide. This index addresses three factors in particular:

  • Size of the problem: the prevalence of modern slavery in each country
  • Government response: governmental response to the problem of modern slavery
  • Vulnerability: factors that explain/predict the presence of modern slavery


The Global Estimates of Modern Slavery

The Global Estimates of Modern Slavery is another global indicator of modern slavery worldwide, which was developed by the International Labour Organisation (ILO) and the International Organisation for Migration (IOM). This indicator provides the estimates for modern slavery globally. These estimates were used as a starting point for the Global Slavery Index.


Contractual Obligation

We include our standard modern slavery clauses in our supplier contracts and purchase orders’ standard terms and conditions. We go through an escalation and sign off process with the business to consider the risks of any supply contract. These clauses seek to manage modern slavery risks and ensure that we receive appropriate information on suppliers’ supply chains and organisations, including copies of their modern slavery statements if they are required to report under the UK Modern Slavery Act.

Our suppliers have a contractual obligation to ensure compliance with all applicable laws that apply to their supply of goods and services to us, regardless of the jurisdiction in which they operate. This includes the UK Modern Slavery Act and any local legislation that is aimed at combating modern slavery.



Catalystpay has developed training materials that focuses on how we mitigate the risk of modern slavery and human trafficking in our supply chain, our third parties, and customer base and direct operations. We annually refresh the materials with updated real-life examples of how business can be exposed to modern slavery risks, as well as additional information on the evolving global regulatory landscape. The training is mandatory for all employees at Catalystpay (including temporary workers).

As part of our training, we are encouraging people to report any signs of modern slavery and human trafficking to Unseen UK. All reports will be received by the Modern Slavery Helpline, which works closely with law enforcement agencies, non-governmental organisations, as well as media organisations. The training aims to develop employee awareness of what constitutes criminal activity, the indications of this and how to report concerns of suspicious activity.