Modern Slavery Statement

Modern Slavery, Child Labor, and Human Trafficking

1.0 Introduction

This statement for the financial year ending 31 December 2024 is made by Accertify, Inc. and Accertify (UK) Limited (together “Accertify”) in accordance with Section 54(1) of the Modern Slavery Act 2015 (the “Act”) and the United States prohibition on trafficking in persons (48 CFR 52.222-50).

This statement sets out Accertify’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery, child labor, or human trafficking in its business and supply chains. Accertify understands that it has a responsibility to take a strong stance on illegal activity and is absolutely committed to preventing slavery, child labor, and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery, child labor, and human trafficking.

2.0 Our Business

Accertify is a global company offering fraud and risk protection services to businesses around the world. In the United States, Accertify’s activities are carried out by Accertify, Inc., which is registered in the state of Delaware. In the UK, Accertify’s activities are carried out by Accertify (UK) Limited, which is incorporated in the UK. Accertify is committed to the highest ethical standards within both its business and supply chain and expects the same standards from its suppliers.

3.0 Our People

Accertify carries out compliance checks on all new employees to ensure that they have the right to work in the market where they are hired. In addition, Accertify requires that suppliers of contract or temporary resourcing carry out their own checks of individuals’ rights to work in the market where their hiring occurs.

Action will be taken against employees who violate the prohibition on modern slavery, child labor, or trafficking, up to and including termination. Employees should report, without fear of retaliation, activity inconsistent with the prohibition trafficking in person. Any credible information Accertify receives alleging an employee or subcontractor has engaged in conduct that violates the prohibition on modern slavery, child labor, or trafficking should be reported to the Accertify Legal team (legal@accertify.com), who will report the credible information to the appropriate authorities. The phone number of the Global Human Trafficking Hotline is 1-844-888-FREE and its email address is help@befree.org

4.0 The Risks

The principal areas of risk related to slavery, child labor, and human trafficking, include: 1) some components of our supply chain; and 2) temporary service staff. Accertify considers its exposure to slavery, child labor, and human trafficking to be low due to the nature of its industry and its location. Accertify has further taken steps through the implementation of Accertify’s policies and training programs and to ensure that its business or any business that provides goods or services do not violate its Modern Slavery and Human Trafficking Statement. These risks are further managed through procedures set forth in this policy.

5.0 Supply Chain

Accertify Procurement is responsible for governance of the Company’s third-party management program. This includes, but is not limited to, facilitating the efficient and effective use of company resources in the acquisition of goods and services from third-party suppliers, while protecting the Accertify brand and other financial assets, and complying with company policy and regulatory requirements. The Procurement team is responsible for performing risk assessments, collecting and reviewing the sufficiency of due diligence required from suppliers, selective validation of ongoing oversight documentation and reporting on third-party risk.

6.0 Recruitment

Accertify’s Human Resources Department follows the Modern Slavery and Human Trafficking Statement and only uses reputable recruitment and or temporary agencies that comply with the Modern Slavery and Human Trafficking Statement. To reduce the potential for slavery, child labor, and human trafficking, Accertify investigates the agencies’ reputations for sound business and ethical practices and asks that the agencies provide assurances that appropriate checks have been made on the persons they are supplying to ensure compliance with Accertify’s policies.

7.0 Policies and Due Diligence

As a fraud and risk services provider to businesses we have evaluated the risk of slavery, child labor, and human trafficking from occurring within our supply chain as low. As part of our ongoing commitment to the highest ethical standards we leverage the following as ways in which Accertify can further mitigate any risk:

• All employees at Accertify are required to complete Code of Conduct training on an annual basis. Failure to do so constitutes a disciplinary offence. The Code of Conduct sets the highest ethical standards and requires employees to report any suspicion of non-compliant and/or unethical behavior (which would include breaches of the Act) either by Accertify or any of its business partners, including but not limited to suppliers.
• All employees at Accertify are required to follow the organization’s values, which are the principles that guide how we carry out our business and interact with our people and communities. We aim to deliver exceptional service to our clients by building long-lasting relationships based on trust and understanding, and the same approach applies to our relationships with suppliers. Further, employees interact with suppliers, managing risks, analyzing data, and ensuring compliance with laws and regulations. Our employees work together across business lines and communicate effectively to ensure all supplier engagement activities are conducted with integrity.
• When Procurement contracts with a supplier it stipulates inter alia that: (1) suppliers must comply with all applicable laws when providing goods and/or services to Accertify; (2) appropriate background checks must be carried out on all supplier personnel; and (3) sub-contracting is generally prohibited without the express consent of Accertify.
• The Third-Party program within Procurement is a comprehensive and rigorous approach to managing third-party relationships throughout their entire lifecycle. The program ensures that we appropriately oversee our third-party relationships and comply with strict regulatory requirements in relation to governance, oversight and documentation. The risk assessment model covers several risk categories ranging from strategic and business risk to reputational risk and credit risk.
• The Anti-Corruption Due Diligence program, including, but not limited to Accertify’s Anti-Bribery and Corruption policy, is designed to prevent the misuse of Accertify funds to further corruption; to protect Accertify and its employees from criminal and civil liability by prohibiting activities that violate applicable laws; and to prevent employees and third parties from engaging in bribery on Accertify’s behalf. These policies further encourage its employees to speak up and report any potential wrongdoing.

8.0 Steps to Measure Effectiveness

Accertify has created awareness of modern slavery issues through its training program for its employees with an emphasis on reporting any potential wrongdoing.

9.0 Revision History

10.0 Sign Off

Name: Mark Michelon
Title: President
Date: Nov 27, 2024