Modern Slavery and Human Trafficking Statement

The statement sets down Form3’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Employees are expected to report their concerns and management to act upon them. We are a low risk Fintech business focused on delivering cloud-based connectivity, payment processing, clearing and settlement services. Our customers include a wide range of regulated financial institutions, including leading banks, non-bank financial institutions and Fintechs. Our head office is based in London and all of our employees are contracted from the UK, US, Argentina, Canada, or within the EU.

Form3 has deployed a company-wide salary benchmarking process to ensure that employees are paid fairly and in line with market. Additionally, we ensure that all employees of Form3 Group Limited, its subsidiaries, and contractors are paid at London living wage levels or higher.

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, Form3 has deployed a company-wide modern slavery briefing which forms part of the annual Form3 Employee Policy and Procedure self-attestation process.

Form3 is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms this intention to act ethically in our business relationships.

We operate a number of internal Form3 policies to ensure that we are conducting business in an ethical and transparent manner. These include:

• Recruitment – we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees and contractors to safeguard against human trafficking or individuals being forced to work against their will.
• Whistleblowing – our whistleblowing policy ensures that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisal.
• Equality and Diversity – this policy is designed to ensure the fair treatment of our employees and potential employees.
• Health and Safety – this policy sets out our approach to ensure we provide a healthy working environment for our staff and contractors that work out of our premises and from home.

Form3 undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers.

We aim to identify any material Modern Slavery and Human Trafficking concerns as a part of our supplier due diligence and performance reviews process. The specific steps that are necessary to identify the Modern Slavery and Human Trafficking concerns may vary based on each vendor.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Management Team and Board of Directors endorses this policy statement and is fully committed to its implementation.

We use the following KPls to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• 100% of employees and contractors of the business are required to read and attest to our Modern Slavery and Human Trafficking Statement
• 100% of breaches of this Statement are reported to the CEO and the Anti-Slavery Compliance Officer
• 100% of breaches are assessed within a reasonable time of being reported and further investigations concluded as soon as possible thereafter
• 100% of employees and contractors employed by, or engaged with Form3 are paid at least at London Living Wage levels

We have appointed an Anti-Slavery Compliance Officer, Prashanta Chettri, who will take responsibility for our ongoing actions to combat slavery and human trafficking.

We intend to take the following further steps to combat slavery and human trafficking: 

• Risk assess all new suppliers using the Global Slavery Index and ask them to certify that they have taken steps to eradicate modern slavery within their own organisation and supply chain; 
• Where applicable, incorporate anti-slavery and human trafficking obligations into material 3rd party vendor contracts; 
• Include appropriate measures in our due diligence processes for sourcing suppliers, subcontractors and acquisitions on a risk assessed basis; 
• Provide further training to relevant employees to ensure a high-level understanding of the risks of modern slavery and human trafficking; and 
• Where appropriate we will include reference to the Modern Slavery Act 2015 in our policies and procedures. 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Form3’s slavery and human trafficking statement for the current financial year. 

Mike Walters
Form3 Group Limited
CEO

Date: March 2024