Modern Slavery & Human Trafficking Statement

eCOMM Merchant Solutions Group

Pursuant to the requirements of the 'UK Modern Slavery Act 2015' and 'Recommendations for the Identification of Victims of Trafficking in Human Beings, Pre-Trial Investigation and Inter-Institutional Cooperation 2015' in Lithuania we, eCOMM Merchant Solutions Group, strive to ensure that modern slavery or human trafficking does not exist within our business or supply chain.

The eCOMM Group has implemented several policies which reflect our objective to act ethically and in compliance with our legal and regulatory obligations with regard to our employees, customers and our business relationships.

The Group Code of Conduct represents the standards of behaviours expected of all employees of the eCOMM Group.

The Group Whistleblowing Policy sets out the procedure our employees should follow if they have suspicion or concerns about any wrongdoing, unlawful conduct, bribery, financial malpractice, dangers to the public or the environment, or possible fraud or other risks to the eCOMM Group.

The Group Recruitment Policy aims to ensure that our recruitment and selection processes are designed and conducted fairly.

Group Anti-Bribery and Corruption Policy sets out the rules with regard to bribery and corruption that apply to all our directors and employees.

Group Anti-money Laundering and Counter Terrorist Financing Policy sets out the steps we take to prevent the commission of financial crime, money laundering and terrorist financing.

Group Outsourcing and Vendor Management Policy sets out the requirements for the effective and consistent third-party management. We conduct due diligence that includes assessment of our vendors' reputation and policies.

We are focussed on raising awareness of the policies listed above and providing a relevant training across our Group.

Responsibility for ensuring that the eCOMM Group has appropriate policies in place to meet our legal and regulatory obligations, rests with the Boards of Directors of the impacted Group's entities. This statement and the underlying policies cited herein are reviewed by said Boards annually.