Modern Slavery Policy

1. Statement Overview

This statement is made on behalf of Paytia Limited pursuant to section 54(1) of the Modern Slavery Act 2015 and comprises our slavery and human trafficking statement for the financial year ending 31st March 2026.

2. Our Business

Paytia Limited is a UK-based technology company that provides secure payment processing solutions and telephony services to businesses worldwide. We manage a business platform as a service product set, enabling organisations to process payments securely while maintaining PCI DSS compliance.

Our operations include:

• Secure payment capture and processing services
• Telephony integration solutions
• API services for business system integration
• Compliance and security consulting

3. Our Supply Chains

Our supply chains consist primarily of:

• Technology service providers and cloud infrastructure partners
• Software development and professional services contractors
• Telecommunications and connectivity providers
• Office services and facilities management
• Legal, accounting, and professional advisory services

Given the nature of our technology-focused business, our supply chain risks are generally lower than those in manufacturing or labour-intensive industries. However, we remain vigilant about potential risks in our extended supply chain.

4. Our Policies

Paytia has implemented several policies that contribute to ensuring modern slavery does not occur in our business or supply chains:

Code of Conduct

Our Code of Conduct sets out the standards of behaviour expected from all employees and reflects our commitment to acting ethically and with integrity in all business relationships.

Supplier Code of Conduct

We require our suppliers to adhere to our Supplier Code of Conduct, which includes specific provisions prohibiting the use of forced, compulsory, or trafficked labour and child labour.

Whistleblowing Policy

We have a whistleblowing policy that encourages employees and others to report any concerns, including those related to modern slavery, without fear of retaliation.

5. Due Diligence Processes

As part of our commitment to identifying and mitigating the risk of modern slavery in our business and supply chains, we have implemented the following due diligence processes:

Supplier Assessment

• All new suppliers are required to complete a supplier assessment form
• We conduct background checks on key suppliers and partners
• Contracts include specific clauses prohibiting modern slavery
• We reserve the right to audit suppliers' compliance with our standards

Risk Assessment

• We assess the modern slavery risks associated with our business activities
• We consider geographical and sector-specific risks when selecting suppliers
• Higher-risk suppliers undergo enhanced due diligence

6. Risk Assessment and Management

We have assessed our business operations and supply chains for modern slavery risks and identified the following areas of focus:

Low Risk Areas

• Direct employees in the UK
• Major technology vendors and cloud service providers
• Professional services firms (legal, accounting, consulting)

Areas Requiring Monitoring

• Subcontractors in technology development
• Facilities management and cleaning services
• Hardware suppliers and manufacturers

7. Key Performance Indicators

To measure our effectiveness in ensuring modern slavery is not occurring in our business or supply chains, we track:

• Percentage of suppliers who have completed our modern slavery assessment
• Number of modern slavery-related concerns reported through our whistleblowing channels
• Completion rates for modern slavery training among employees
• Number of supplier audits conducted with modern slavery components

8. Training and Awareness

We provide training and awareness programmes to ensure our employees understand:

• The Modern Slavery Act 2015 and its requirements
• How to identify potential signs of modern slavery
• Our policies and procedures related to modern slavery
• How to report concerns or suspicions

Training is provided to:

• All new employees during induction
• Procurement and supplier management teams
• Senior management and directors
• Any employees involved in supplier relationships

9. Further Steps

During the next financial year, we plan to:

• Conduct a comprehensive review of our existing suppliers against modern slavery criteria
• Implement enhanced due diligence procedures for higher-risk supplier categories
• Develop specific KPIs to measure our modern slavery prevention effectiveness
• Provide additional training to procurement and management teams
• Review and update our supplier contracts to strengthen modern slavery provisions

10. Governance and Approval

This statement has been reviewed and approved by Paytia's Board of Directors. We are committed to continuous improvement in our approach to preventing modern slavery and will review this statement annually.

Any questions or concerns about this statement should be directed to our compliance team at: compliance@paytia.com.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Paytia Limited's slavery and human trafficking statement for the financial year ending 31st March 2026.