Modern Slavery Statement

This Statement sets Spend Ltd’s commitment to preventing slavery and human trafficking in all our business activities and the steps we have put in place with the aim of ensuring that slavery or human trafficking is not in place in our supply chains or in any part of our business.

We all have a duty to be alert to risks however small and our employees, officers and contractors are expected to report their concerns to management to act upon them.

This statement affirms our intention to act ethically in our business relationships.

Spend Ltd is a low-risk business, focused on delivering payment-based services, payment processing, clearing and settlement services. Our customers are Individual, Corporates and Financial Institutions. Our suppliers are industry leaders in their respective fields.

Our office is based in London and all of our employees are contracted from the UK.

Remuneration

Spend Ltd has deployed a company-wide salary benchmarking process to ensure that employees are paid fairly and in line with the market standards.

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include, but are not limited to, the following:

• Whistleblowing Policy
• Vendor Selection Policy
• Risk Management Framework and underlying policies.

Due Diligence Processes for Slavery and Human Trafficking

Spend Ltd undertakes due diligence when considering taking on new customers and suppliers and regularly reviews its existing suppliers and client base.

The Modern Slavery and Human Trafficking Statement

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Management Team and Board of Directors endorses this policy statement and is fully committed to its implementation.

We intend to take the following further steps to combat slavery and human trafficking:

• Risk assess all new suppliers using the Global Slavery Index and ask them to certify that they have taken steps to eradicate modern slavery within their own organisation and supply chain;
• Where applicable, incorporate anti-slavery and human trafficking obligations into material third party vendor contracts;
• Include appropriate measures in our due diligence processes for sourcing suppliers, subcontractors and acquisitions on a risk assessed basis;
• Provide further training to relevant employees to ensure a high-level understanding of the risks of modern slavery and human trafficking; and
• Where appropriate we will include reference to the Modern Slavery Act 2015 in our policies and procedures.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Spend Ltd’s slavery and human trafficking statement for the current financial year.