Modern slavery statement

1. Organisation

This statement applies to Alternative Payments Limited t/as Judopay (referred to in this statement as ‘the Organisation’ and “Judopay”). The information included in the statement refers to the financial year 2018/2019.

2. Organisational structure

Judopay is proud of the steps taken to combat slavery and human trafficking. As a company that has a zero-tolerance approach to modern slavery and is committed to acting with integrity in all its dealings to implementing and enforcing effective controls and systems to ensure that modern slavery is not taking place anywhere in the business or any of the partner’s supply chains. Judopay is committed to ensuring transparency and expect the same high standards from all of its contractors, suppliers and other business partners.

Judopay is a limited company registered and based in England and Wales specialised in payment services with a focus on mobile payment solutions. As an established business in the European financial market, Judopay is a trusted partner from the main acquiring banks and a reputable provider amongst European market-leading brands. The Organisation is controlled by a Board of Directors.

The main activity performed by the Organisation is the provision of mobile payment services, connecting merchants, end customers, partners, and businesses, secure and reliable payment experience in accordance with the Cars Schemes requirements. The demand for Judopay’s payment solution is consistently high throughout the year and is therefore not seasonal.

3. Definitions

Judopay considers that modern slavery encompasses:

  • Human trafficking;
  • Forced work, through mental or physical threat;
  • Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
  • Being dehumanised, treated as a commodity or being bought or sold as property;
  • Being physically constrained or to have a restriction placed on freedom of movement.

4. Commitment

Judopay acknowledges its responsibilities concerning modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices concerning its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Judopay in the pursuance of the provision of its services is obtained employing slavery or human trafficking. The Organisation strictly adheres to the minimum standards required concerning its responsibilities under relevant employment legislation in England and Wales and Australia, and in many cases exceeds those minimums concerning its employees.

5. Supply chains

To fulfil its activities, Judopay’s main supply chains include those related to payment services from various financial and technology providers in both the United Kingdom and Europe. Judopay understands that the Organisation's first-tier suppliers are European Acquiring Banks and technology, providers.

Judopay procures a wide range of services via a varied supply chain, including:

  • Financial Service Providers
  • Payment Technology Providers
  • Facilities Management Services
  • Communications and IT equipment Services
  • Temporary/Agency Staff
  • Recruitment Agencies
  • Compliance Advisories
  • Office Equipment and Supplier Services

We evaluate and address the risks of modern slavery and human trafficking amongst our suppliers by adhering to these standards:

  • Our suppliers must not use forced labour - slave, prison, indentured, bonded, or otherwise,
  • Our suppliers must not traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction, or fraud. Working must be voluntary, and workers must be free to leave work and terminate their employment or another work status with reasonable notice.
  • Workers shall not be required to pay recruitment, hiring, or other similar fees related to their employment; our suppliers must bear or reimburse to their workers the cost of any such fees. All fees and expenses charged to workers must be disclosed to Amazon and communicated to workers in their native language in advance of employment.
  • Our suppliers must not require workers to surrender government-issued identification, passports, or work permits as a condition of working, and our suppliers may only temporarily hold onto such documents to the extent reasonably necessary to complete legitimate administrative and immigration processing.
  • Workers must be given clear, understandable contracts regarding the terms and conditions of their engagement in a language understood by the worker.
  • Suppliers must ensure that each of its staffing or recruiting agencies comply with this Supplier Code and with the more stringent of the applicable laws of the country where work is performed and the worker’s home country.

6. Potential exposure

In general, Judopay considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

We use a combination of desk-based research, supply chain mapping, as well as internal and industry audit results to analyse the risk of modern slavery in our supply chain and operations. While modern slavery can be found in all countries and industries, we acknowledge that there is a heightened risk with:

  • domestic and international migrant labour;
  • contract, agency, and temporary workers;
  • vulnerable populations (e.g. refugees); and
  • young, or student workers.

7. Due diligence

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

Judopay has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Judopay has taken the following steps to ensure that modern slavery is not taking place:

  • Periodically reviewing the supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;
  • Adopted measures to identify and assess the potential risks in its supply chains such as periodic due diligence process;
  • Creating action plans to address the risk to modern slavery;
  • Carrying out regular reviews to ensure suppliers are assessed and the information held on the supply base is kept up to date;
  • In terms of employee recruitment, undertaking all relevant pre-employment checks to ensure the eligibility to work in the United Kingdom and transparent recruitment processes to ensure that the Organisation recruitment agencies comply with these requirements in the provision of agency staff;
  • Supporting mental health at work programs and practices within the Organisation’s activities.

8. Policies

The Organisation has the following policies which further define its stance on modern slavery:

  • Supplier Management Policy;
  • Recruitment Policy;
  • Health and Safety Policy;
  • Operational Security Policy;
  • HR Equality & Diversity Policy.

9. Compliance Officer

Judopay has a Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.