Global Payments UK Limited
Slavery and Human Trafficking Transparency Statement
The Modern Slavery Act 2015 came into effect on 29 October 2015 and requires each
company conducting business in the UK and having annual turnover of at least £36 million
to provide information regarding the steps it has taken to prevent slavery and human
trafficking from occurring within its business and supply chain. We fully support the aims
of the Act, and this statement sets forth the steps we have taken to eradicate slavery,
forced labour and human trafficking from our business.
We make this statement with respect to our financial period ended 31 December 2016
and on behalf of our affiliate GPUK LLP.
We are a UK-based subsidiary of Global Payments Inc., a leading worldwide provider of
payment technology services delivering innovative solutions to customers globally. As
part of a multinational corporation, we distribute our services across a variety of channels
to merchants and partners throughout North America, Europe, the Asia-Pacific region and
Brazil. We work with global suppliers across a number of different industries including
businesses with operations in each of the geographic regions where we distribute our
We are committed to upholding the highest ethical standards in all of our corporate
activities. In connection with this commitment, we have adopted an Employee Code of
Conduct and Ethics. Our Code of Conduct sets out the internal policies which all of our
employees are required to follow in the course of their employment and representation
of the Company. All employees must understand and comply with the Code of Conduct,
and we deliver annual training on the Code of Conduct to underscore the Company’s
commitment to conducting business with integrity and in an ethical manner.
Our Supply Chain
In addition to conducting our business in accordance with our Code of Conduct, we strive
to ensure that our supply chains do not contribute toward slavery, forced labour or
human trafficking. We are committed to partnering only with suppliers who share our
standards and our commitment to conducting business in an ethical manner, and we seek
to identify suppliers who have taken steps to prevent slavery and human trafficking within
their own businesses and supply chains. Following is a summary of some of the steps we
have taken to ensure that our suppliers meet these standards.
Vendor Management Program. We have developed a comprehensive Vendor
Management Program which governs our engagements with each of our vendors and
suppliers across the Company. The Vendor Management Program involves checkpoint
reviews prior to and throughout the course of our relationship with each supplier which
allow us to confirm that our suppliers conduct business in accordance with our
Risk Assessment and Due Diligence. Prior to entering into a relationship with a new
supplier, we conduct due diligence activities to assess the risks of partnering with that
supplier and to provide assurance that the supplier meets expectations regarding
adequate controls. As part of these due diligence exercises, we require that our suppliers
are compliant with applicable laws related to forced labour and human trafficking and
that they have implemented appropriate controls to ensure forced labour and human
trafficking do not occur within their businesses or their own supply chains.
Worldwide Terms & Conditions. Our contracts with our suppliers contain specific terms
and conditions which require our suppliers to comply with all applicable laws and
regulations in their provision of goods or services and to conduct their business in
accordance with our standards and expectations. We reserve the right to terminate our
contracts with suppliers for noncompliance with such laws, regulations and standards.
Ongoing Monitoring. We conduct ongoing monitoring of our suppliers to ensure that they
are compliant with their contractual commitments and are delivering products or services
in accordance with our standards. Suppliers which present heightened risks may be
subject to additional audits or reviews.
This statement has been approved by the directors of Global Payments UK Limited.
Director, Global Payments UK Limited