Anti-Slavery Policy
Zero tolerance for modern slavery.
Our position on modern slavery, forced labour and human trafficking — in our own business, in our supply chain, and among the businesses we are asked to introduce.
Our commitment. RimonPay has zero tolerance for modern slavery, forced labour, debt bondage and human trafficking. We will not tolerate it in our own operations, we expect the same standard of everyone we work with, and we will not knowingly introduce a business that we believe benefits from it.
A note on the law. Section 54 of the Modern Slavery Act 2015 requires organisations carrying on business in the UK with a total turnover of £36 million or more to publish an annual slavery and human trafficking statement. RimonPay [is / is not] above that threshold. We publish this policy voluntarily as a statement of our standards, whether or not we are legally required to. [Confirm your turnover position. If you are above the threshold, this policy must be published as your statutory annual statement, approved by senior management and signed, and must cover the six areas required by section 54(5).]
01Purpose and scope
This policy sets out the steps RimonPay takes to prevent modern slavery and human trafficking in its business and supply chain. It applies to all personnel, contractors, suppliers, professional advisers and partners, and to the businesses we are asked to introduce to acquirers.
02Our business and our risk
RimonPay provides an introduction service from the UK. We do not manufacture, source or distribute physical goods, and we do not operate overseas sites or engage low-cost labour directly. Our direct exposure to modern slavery in our own operations is therefore limited.
Our risk arises indirectly, in two places: the supply chain of the technology and services we buy, and — the more significant area — the business models of the merchants we are asked to introduce. We are alert to sectors and models where labour exploitation is more likely, including certain forms of manufacturing, agriculture, construction, food processing, cleaning, care and hospitality, and to any business showing signs of exploitative labour practices.
03Our standards
We expect, and require of our own operations, that:
- employment is freely chosen, and no one is forced, coerced or trafficked into work;
- workers are not subject to debt bondage, and no worker pays a fee to obtain or keep a job;
- identity documents and passports are never withheld;
- workers are free to leave employment on reasonable notice, and are not subject to threats, intimidation or violence;
- child labour is never used, and no one under the local minimum working age is employed;
- wages meet or exceed legal minimums, are paid on time, in full, and in a lawful manner;
- working hours comply with the law, and workers receive the rest and leave they are entitled to;
- working conditions are safe and lawful, and workers are treated with dignity and without discrimination.
04Due diligence
- Suppliers and service providers — we assess modern slavery risk before engaging a supplier and during the relationship. New suppliers are asked about their own labour practices and any relevant policies, and higher-risk suppliers are asked for more. Where we identify a concern, we require it to be addressed or we end the relationship.
- Partners — we expect acquirers and other partners to hold standards equivalent to ours, and we take account of their published statements and policies.
- Merchants — where a business we are asked to introduce shows indicators of labour exploitation, we will not proceed, and we will report a concern where appropriate.
05Recruitment practices
We recruit directly and do not use labour providers, recruitment agencies that charge workers, or any arrangement in which a worker pays a fee to obtain a role. All workers are engaged on written terms, paid directly, and given the information they need about their rights.
06Reporting a concern
Anyone — a member of our team, a supplier, a merchant, or a member of the public — who has a concern about modern slavery connected to RimonPay or a business we are introducing should tell us. Reports may be made confidentially to sales@rimonpay.com, or by post to [postal address].
- We treat all reports seriously and investigate them promptly.
- No one will suffer any detriment for reporting a concern in good faith.
- Where a concern suggests a criminal offence or a risk to a person’s safety, we will involve the police or another appropriate authority. Urgent concerns about a person at risk should also be reported to the police directly.
07Training and awareness
Our personnel receive awareness training covering the forms modern slavery takes, the indicators to look for in a merchant file or a supply chain, and how to report a concern. Training is given on joining and refreshed at least annually.
08Monitoring and review
This policy is reviewed at least annually. The review considers our supply chain, any concerns raised, any incidents, and whether our due diligence remains proportionate. Where we identify a failure, we take steps to address it and record what we have done.
09Approval and contact
This policy is approved by senior management of RimonPay. Questions should go to sales@rimonpay.com.