Modern Slavery Act Transparency Statement
Last Updated: 2023-08-09
Zafin’s Global Business
As a global company Zafin pursues the highest standards of corporate responsibility in all we do — supporting and empowering employees, working with clients and suppliers, and governing our company. Internally, the issue of prevention of human trafficking is a shared responsibility across the organizations and other areas of social responsibility.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
We are committed to supporting and respecting internationally proclaimed human rights. As a signatory to the United Nations Global Compact since 2021, we adhere to the 10 Principles of the Global Compact and to the United Nations Guiding Principles.
Zafin’s commitment to doing business responsibly, ethically, and legally is the foundation for the company’s global culture and is espoused by all its people. We expect all our people to treat each other, and those we deal with, respectfully and with dignity. We do not tolerate physical violence, threats, corporal punishment, mental coercion, verbal abuse, disrespectful behaviour, bullying or harassment of any kind. We actively encourage our people to raise ethical and legal concerns, including any concerns about human rights issues, and we make multiple channels available for them to do so—including anonymously, where legally permitted, see Code of Business Conduct. We also stress that we have zero tolerance for retaliation against anyone who speaks up in good faith. Zafin investigates any potential human rights breach it becomes aware of and seeks to appropriately remedy or mitigate those breaches.
Managing the Risk of Modern Slavery
As well as having the requisite contractual controls in place, there are rigorous on-boarding checks defined by our HR team. These are carried out on all individuals working at Zafin locations. Zafin has continued to take steps to identify and manage those areas in our supply chain where we believe modern slavery and human trafficking are a possibility. Our goal remains to identify and minimise the risk wherever possible and to continually monitor and improve in our efforts.
Our Supplier Standards of Conduct
We believe that the nature of our business, as a provider of SaaS predominantly to global banks, means that we are not directly exposed to a high risk of modern slavery and human trafficking.
We are nonetheless keenly aware that the possibility does exist within our global supply chains, particularly in the context of certain of our inter-company shared service suppliers located in countries considered to be of higher risk in the context of modern slavery and human trafficking. In order to mitigate this risk, we work alongside our procurement team and endeavour to establish adequate procedures to tackle the risk of modern slavery and human trafficking in supply chains and ensure their policies reflect appropriate standards for their business.
Our Supply Chain processes include both due-diligence checks before we enter into contracts with suppliers and regular ongoing risk monitoring to ensure the risk profile of a supplier has not changed. Our approach to risk monitoring and due diligence is reviewed on a regular basis and we seek to improve these processes continually, through supplier engagement, raising awareness of issues and requirements, and by delivering training to our key staff, who manage the relationships with our suppliers. We understand the importance of this and will continue to invest in our capabilities in our Procurement and supplier risk management.
More broadly, the relationship between Zafin and our Zafin suppliers is a critical component of our support for human rights. Consistent with Zafin’s standard procurement process, we require all Zafin suppliers to comply with our global Supplier Standards of Conduct or to make an equivalent commitment. Our Standards of Conduct reflect our core values, our ethical principles, and our commitment to human rights. They set out clearly the labour standards that Zafin suppliers must adhere to, particularly in relation to slavery and human trafficking. We seek to encourage a culture of transparency within our supply chains and provide a mechanism to enable employees of Zafin suppliers to speak up about legal or ethical concerns, including slavery and human trafficking. Employees of Zafin suppliers may report concerns or violations (anonymously where permitted by local law) through the Zafin Business Ethics Helpline. To date, we have not received through this Helpline, or otherwise, any complaints from third parties raising concerns about slavery or human trafficking.
Our Policies in relation to Modern Slavery
All relevant business-wide policies include appropriate reference to and consideration of the risk of MSHT. Our Zafin Code of Business Conduct and Policies includes procedures on:
- Compliance with Laws
- Ethical Business Practices
- Conflicts of Interest
- Code of Conduct
- Raising Legal and Ethical Concerns & Grievances Policy
- Global Policy on Prohibition of Human Trafficking Forced Labor and Child Labor
Our procedures are designed to ensure that behaving ethically towards our customers, employees and suppliers is at the heart of our business.
We actively encourage our people to raise ethical and legal concerns, including any concerns about human rights issues, and we make multiple channels available for them to do so—including anonymously, where legally permitted. See Global Policy on Raising Legal and Ethical Concerns & Grievances.
We also stress that we have zero tolerance for retaliation against anyone who speaks up in good faith. Zafin investigates any potential human rights breach it becomes aware of and seeks to appropriately remedy or mitigate those breaches.
We have a Global Policy on Prohibition of Human Trafficking Forced Labor and Child Labor expressly prohibiting our employees from engaging in or supporting human trafficking, forced labour and child labour in connection with Zafin’s activities, including in our supply chains.
We continue to review our human rights efforts, as well as best practices in the marketplace, to understand how we can further strengthen our commitment to ensure slavery and human trafficking are not taking place within our organisation or our supply chains. An important component of our review of best practices is our active membership of the UN Global Compact UK Network’s Modern Slavery Working Group. We continue to strengthen our targeted employee awareness of the need to ensure that human rights are protected within our own business and within our supply chain and the need to enforce our Code of Conduct and to benchmark our own approach and strategies against those of other industry peers and thought leaders.