Modern Slavery Statement

Introduction

SAPI is a London-based fintech company that offers loan-programs-as-a-service to payment companies and marketplace worldwide. We enable payment companies to provide white-label SME financing products to their business merchants who utilise the partners’ services.

This statement outlines SAPI’s commitment to detecting and preventing modern slavery. At SAPI, we maintain a zero-tolerance stance towards modern slavery and human trafficking, and we are dedicated to conducting our business responsibly. Acting with integrity and transparency is at the core of our company culture, which is fostered by our Board of Directors and CEO.

Policy Statement

Modern slavery encompasses crimes such as slavery, servitude, forced and compulsory labor, and human trafficking. These offenses involve depriving individuals of their liberty in order to exploit them for personal or commercial gain. We are fully committed to upholding ethical practices and integrity in all our business relationships and transactions. To ensure modern slavery is not present within our own business or supply chains, we implement effective systems, controls, and enforcement measures.

Furthermore, we are dedicated to maintaining transparency within our business operations and addressing modern slavery in our supply chains, in line with our obligations under the Modern Slavery Act 2015. We hold our contractors, suppliers, and business partners to the same high standards that we set for ourselves. Our contractual processes explicitly prohibit the use of forced, compulsory, or trafficked labor, as well as any form of slavery or servitude, for both adults and children. We also expect our suppliers to maintain these high standards with their own suppliers.

This policy applies to all individuals working for or on behalf of SAPI, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

Responsibility for Policy

The Board of Directors assumes overall responsibility for ensuring compliance with legal and ethical obligations related to this policy, and for ensuring that all individuals under our control adhere to it. The Head of Compliance holds primary responsibility for implementing and monitoring this policy’s effectiveness, handling inquiries, and conducting internal audits of control systems and procedures to combat modern slavery. All levels of management are accountable for ensuring that their subordinates understand and comply with this policy. Adequate and regular training on this policy and the issue of modern slavery in supply chains is provided to our staff. We welcome your comments on this policy and any suggestions for improvement. Please address any comments, suggestions, or queries to compliance@sapi.com.

Our Employees

At SAPI, we are proud to have a strong set of shared values that form the foundation of our business. We place significant importance on upholding these values. As part of our onboarding process and annual screening, all staff members undergo background checks. They are also required to complete training programs that cover various aspects of business compliance, anti-financial crime, and data protection.

Policies, Procedures, and Processes

We have established a comprehensive set of policies and procedures that are supported by senior management, promoting the prevention of anti-slavery and human trafficking. We incentivise positive behaviour within our organisation through appropriate incentives. Our relevant policies include:

• Anti-money laundering and counter-terrorist financing.
• Conflicts of interest.
• Anti-bribery and corruption.
• Whistleblowing.
• Data protection.
• Client due diligence.
• Procurement and vendor due diligence.

We encourage both our employees and external individuals to report any concerns or suspicions of modern slavery within our business or supply chains. You can do so by contacting our Compliance at compliance@sapi.com.

Supply Chain Management

Our supply chain at SAPI is straightforward and mainly consists of technology and data suppliers, as well as office facility providers. Additionally, SAPI collaborates closely with several partners to offer the Payment-linked Advance and Instant Payout product.

We acknowledge our responsibility to identify and address any potential violations of the Modern Slavery Act. As a result, we have implemented robust vendor and partner due diligence processes to ensure that all our suppliers operate in alignment with SAPI’s values.

Within our supply chains, we have a strict policy of zero tolerance for slavery and human trafficking. If any evidence of such practices is found, we will immediately terminate the relationship with the supplier involved.

Risk Assessment

Considering the nature of our business, we assess that SAPI faces a low risk of being involved in slavery and human trafficking.