Modern Slavery and Human Trafficking Statement

Our Organisation

OhentPay UK Limited is incorporated in the United Kingdom and is authorised by the Financial Conduct Authority (FCA) under the Payment Services Regulations 2017.

We offer international payment services in 100+ countries and over 30 currencies to eligible businesses and individuals resident in the United Kingdom.

Our Policies on slavery and human trafficking

OhentPay is an ethically driven company and in pursuant to the requirements of the Modern Slavery Act 2015, OhentPay opposes all forms of slavery and human trafficking. As part of our commitment and responsibility towards our customers and businesses, we expect all suppliers and third-party vendors to adhere to the same ethical principles. We are committed to ensuring that all our internal policies reflect this in all our business relationships.

OhentPay has several policies which ensure zero tolerance to slavery and human trafficking. These include:

1. Equal Opportunities: OhentPay protects its staff from unfair treatment, and exploitation, complying with employment laws in the United Kingdom and other countries we operate in. These include ensuring fair pay rates, fair working conditions, fair employment practices, fair employment terms and conditions, and access to training and development opportunities.
2. Whistleblowing Policy: We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals.
3. Vendor and Risk Management Policy: OhentPay ensures that third-party vendors and outsourcing relationships maintain effective systems and controls to ensure it provides a consistently high standard of services to its customers. We also ensure that risk from these third parties are effectively managed and assessed on a regular basis.

Supply Chain and Due Diligence

OhentPay deals with third-party suppliers who provide a wide range of services. We have internal mechanisms to control, assess and mitigate any risk of slavery and human trafficking. OhentPay uses vendor questionnaires to ask third-party supplies important questions such as:

• Industry track record and sector in which it operates
• Operational Jurisdiction
• Regular checks to ensure transparency and maintain standards.

Our supply chains include the following:

1. Customer Support Communication Providers
2. Cloud Providers
3. IT Security Providers
4. Financial Institutions and Payment Processors

Where a supplier uses subcontractors, OhentPay requires such information to be provided to us and that the supplier conducts oversight on the subcontracted services ensuring that they meet the relevant regulatory requirements.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking, OhentPay conducts regular staff training that focuses on how we mitigate the risk of modern slavery and human trafficking in our supply chain, our third parties, our customer base and direct operations. Staff are also encouraged to discuss any concerns that they have.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and human trafficking are not taking place within our business or supply chain if:

• No reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.