Modern Slavery Statement

Published: 16 July 2020

1. Introduction

    Network Merchants Limited (NMI) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and imposes the same high standards on its suppliers. We take our responsibilities very seriously and any form of modern slavery, forced labour or human trafficking will not be tolerated within our operations.

    We take appropriate steps to ensure that we respect and maintain the fundamental human rights of those who are working for or with NMI.

    This statement covers the activities of the NMI Group across both the UK and USA for the financial year end 2020, as required by the Modern Slavery Act 2015.

    2. Our Organisation

      NMI is a global business, providing ISOs, Fintech Innovators and Technologists the freedom to focus on what they do best, liberating them from restricted payment solutions and giving them access to the latest payment technology. We provide payment solutions internationally across in-store, mobile, online and self-service payments. NMI operates in the UK and USA with offices in Bristol, Chicago, Salt Lake City and New York, employing over 180 people across its offices.

      NMI is backed by global private equity firms, Francisco Partners and Great Hill Partner, both of which specialise in investments in technology, specifically payment solutions and FinTech. To find out more about the nature of our business, please visit: https://www.nmi.com/about.

      In order to provide our services, we work with a range of suppliers across different industries. For a list of our suppliers, please visit: https://www.nmi.com/processors-and-devices. We do not work within a supply chain where modern slavery or human trafficking is prevalent but we still remain committed to identifying potential risks and helping to prevent this.

      3. NMI’s Policies

        As part of our commitment to combating modern slavery, we have implemented the following policies:

        • Modern Slavery & Anti-Trafficking Policy: we have an internal policy which covers the fundamental principles outlined in the Modern Slavery Act 2015, sets out how our staff can identify key signs of modern slavery and trafficking, as well as explaining how our employees should deal with a situation where they think someone is at risk.
        • Procurement Process: as part of our appointment of suppliers, we undertake a risk assessment of the organisation and ask each company to complete a questionnaire which helps us to identify potential risks of modern slavery or human trafficking within their organisation. This is managed through a risk-based approach in light of the services we’re procuring. We ask all companies we work with to adopt the same standards that we apply to our business. We also include anti-slavery clauses in our contracts with our customers and supply chain.
        • Recruitment: We operate a fair and transparent recruitment process which is detailed in both our staff handbook and, for these purposes, specific detail about recruitment is included in our Modern Slavery & Anti-Trafficking Policy. This applies whether we recruiter staff ourselves or whether we use outside agencies.
        • Whistleblowing Policy: we encourage an open culture across all levels of our business and we believe that effective and honest communication is essential if malpractice is to be effectively dealt with. Our staff handbook sets out the process for reporting and we encourage all members of staff to raise any concerns they may have, including those relating to modern slavery or human trafficking.

        The above policies are available to our staff and closely managed by the senior management team.

        We also make sure our suppliers are aware of our policies, and adhere to the same high standards.

        4. Due Diligence

          As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted due diligence procedures designed to:

          • establish and assess areas of potential risk in our business and supply chains;
          • monitor potential risk areas in our business and supply chains;
          • reduce the risk of slavery and human trafficking occurring in our business and supply chains;
          • provide adequate protection for whistleblowers.

          5. Risk and Compliance

          We regularly evaluate the nature and extent of its exposure to the risk of modern slavery occurring in our supply chain by proactively managing those who we work with. We do not consider that we operate in high risk sectors or locations.

          We do not tolerate slavery and human trafficking within our supply chains and if we find evidence of a failure to comply with our policies we will immediately seek to terminate our relationship with the relevant supplier.

          6. Training

            We invest in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

            7. Next Steps

              Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we will continue to monitor our policies and consider developments to our due diligence and risk assessment procedures to help tackle slavery and human trafficking. We recognise that this is an ongoing obligation which continues to apply to NMI and requires a continuing commitment.

              This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes NMI’s slavery and human trafficking statement for the financial year 2019/20.

              This statement was approved by Kyle Pexton on 16 July 2020.