Modern Slavery and Human Trafficking Statement

Introduction

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.

Form3 is the trading name of Back Office Technology Ltd which employs all Form3 employees. 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 office is based in London and all of our employees are contracted from the UK or within the EU.

Compensation

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 Back Office Technology Limited and its contractors are paid at London living wage levels or higher.

Training

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.

Policies

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 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.

Due Diligence Processes for Slavery and Human Trafficking

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

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.

Further steps

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 Back Office Technology’s slavery and human trafficking statement for the current financial year.


Michael Mueller
Back Office Technology Limited
CEO

Date: September 2020