Modern Slavery Statement Information

Modern Slavery Statement

This modern-day slavery statement sets out the risks CCBill have identified in its business relating to modern-day slavery and human trafficking, as well as the commitments it makes as a firm to counteract these risks in the 2021/2022 fiscal year.

Modern-day slavery is a deplorable criminal offence that exploits millions of people every year and deprives them of their autonomy and basic human rights. All companies are at risk of being exposed to modern-day slavery in one form or another, CCBill acknowledges its responsibilities in relation to tackling modern-day slavery and commits to complying with the provisions in the Modern Slavery Act of 2015. This requires an ongoing review of internal practices in relation to its employees, clients, and supply chains.

‘Modern-day slavery’ encompasses the crimes of:

• Human trafficking.
• Forced work, through mental or physical threat.
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse.
• Being dehumanized, treated as a commodity, or being bought or sold as property.
• Being physically constrained or to have restriction placed on freedom of movement.

CCBill’s Organizational Structure

CCBill is an online payment processer that securely handles transactions from all over the world. CCBill is controlled by its Board of Directors, who are ultimately accountable for its business practice, including the implementation of this policy. As an organization, CCBill carries out operations-related services from the US, Malta, the UK and Serbia.

CCBill’s Commitment

CCBill is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its’ supply chains are also free from slavery and human trafficking. As such, CCBill does not conduct business with any other organization, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labor.

No labor provided to CCBill in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. CCBill strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom, United States, Malta, and Serbia, and ensures that in many cases the organization goes beyond those minimums in relation to its employees.

CCBill’s Supply Chains & Potential Exposure

In order to fulfil its activities and provide its services, CCBill has numerous supply chains, including those relating to the procurement of a variety of direct goods and services. CCBill’s supply chains also include highly regarded recruitment agencies that assist in the recruitment of contractors and employees.

CCBill considers its main exposure to the risk of slavery and human trafficking to exist in the recruitment process.

In general, due to the nature of its business, CCBill considers its exposure to slavery/human trafficking to be relatively low. Nonetheless, as a firm CCBill aims to ensure that no business is conducted with any firm, or potential client that may be involved, either directly or indirectly in modern-day slavery.

Relevant Policies

CCBill operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy: CCBill encourages all its workers, clients, and merchants to report any concerns related to the direct activities, or the supply chains of the company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. CCBill provides a confidential system for the protection of whistleblowers’ identity, where possible.
• Employee code of conduct: CCBill’s policies are designed to encourage the highest standards of ethical behavior and employee conduct expected from its employees when representing the company.
• Supplier Procurement code of conduct: CCBill is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labor.
• Recruitment policy: CCBill uses only specified, reputable employment agencies to source employees and contractor and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due Diligence

To its knowledge, CCBill has not conducted any business with another organization which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, CCBill has taken the following steps to ensure that modern slavery is not taking place:

• Reviewing its supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery.
• Measures in place to identify and assess the potential risks in its supply chains.
• Conducting relevant supplier audits or assessments which have a degree of focus on slavery and human trafficking where and if general risks are identified.
• Undertaking impact assessments of its services upon potential instances, or heightened risks of slavery becoming apparent.
• Content reviews of merchants’ websites.
• Assessing risks in the provision of services that CCBill provides.
• Requiring of its suppliers and merchants that they confirm that they do not use forced, or compulsory labor.
• Evaluating the slavery risk of new suppliers, as well as merchant.
• Ensure any CCBill Merchants have effective policies in place that prohibit the use of the merchant’s website in any way that promotes or facilitates human trafficking, sex trafficking or physical abuse.
• Active membership and participation in an anti-human trafficking and/or anti-child exploitation organization is highly recommended to all CCBill merchants.
• Creating action plans to address risk to modern slavery.

CCBill aims to assess its policies, procedures, and processes on an annual basis to ensure that a compliance culture is embodied in its business practices, and to consider whether alternatives policies and/or approaches would be better suited in measuring the effectiveness of its approach to tackling modern-day slavery.

Key Performance Indicators

CCBill has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the organization, its supply chains, or merchants:

• Ensuring all employees have completed training on modern slavery at induction.
• Conducting annual reviews of existing supply chain and carrying out an evaluation all existing suppliers.
• Recruitment process audit.
• Evaluating the number of whistleblowing instances.

Training

As per CCBill’s ‘Training Policy’ all employees are trained on modern slavery policies in their induction during their first two weeks at the company. This training is also repeated on an annual basis and covers the following:

• How to assess the risk of slavery and human trafficking in relation to various aspects of CCBill’s business, including resources and support available.
• How to identify the signs of slavery and human trafficking.
• What initial steps should be taken if slavery or human trafficking is suspected.
• How to escalate potential slavery or human trafficking issues via CCBill’s whistleblowing procedure.

Reporting Concerns of Modern-Day Slavery

CCBill ensures all concerns regarding modern slavery should, and can be addressed, and who will then undertake action with regard to CCBill’s obligations in this regard. Any concerns of modern-day slavery and human trafficking can be addressed to the Head of Compliance.

This statement regarding modern slavery and human trafficking is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed each fiscal year.

Conclusion

CCBill is committed to developing and improving its policies and procedures in order to ensure that appropriate measures are in place to effectively prevent CCBill’s products, operations and supply chain being used in the provision of modern-day slavery.