Anti-Slavery Policy Statement

Acquired Limited has a zero-tolerance approach to any form of modern slavery. We are committed to acting in an ethical manner, with integrity and transparency in all business dealings.

This statement sets out the steps that Acquired Limited has undertaken, and is continuing to take, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

We are committed to creating effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain, and impose those same high standards on our contractors, suppliers and other business partners.

Company structure and supply chains

Born in consumer finance, Acquired is the only custom-built payment solution engineered with a deep understanding of the unique challenges the financial services industry faces. It is these learnings that have enabled us to build a solution that enables modern digital businesses to transact in a single platform, from pay-in to pay-out.

The Acquired intelligent gateway enables increased conversions, a seamless user experience, vastly improved collection rates, greater automation with the dispute management solution and the ability to fully reconcile your payments world with the Perfect Reconciliation tool.

With easy-to-implement technology, a dedicated team and a deep understanding of the payments industry, Acquired provides a world-class, award-winning customised payment solution.

The Acquired payment gateway is built to optimise merchant card collections for businesses in the UK and Europe — enabling them to securely process card, digital wallet and open banking payments via web, mobile and a virtual terminal with improved collections and automation.

Our policies

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

1. Anti-slavery guidance. Acquired Limited's stance on modern slavery, explaining how employees can identify any instances of this and where they can go for help.
2. Resourcing policy. Confirms that eligibility-to-work checks are conducted on all employees, including but not limited to checking an original passport, birth certificate or other qualifying documentation.
3. Whistleblowing policy. Ensures all employees know they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
4. Code of good business practice. Explains the manner in which we behave as an organisation and how we expect our employees to act.

Due diligence processes

As part of our initiative to identify and mitigate risk, we:

• Operate strict procurement processes, requiring suppliers to comply with all applicable laws and standards, including those which relate to the Modern Slavery Act.
• Base our tender documents on the government standard selection questionnaire (SSQ) with specific questions in the ITT response around the Modern Slavery Act and compliance with it.
• Expect our suppliers to have suitable policies and processes in place within their own businesses to prevent child labour, modern slavery and human trafficking, and to cascade those policies to their own suppliers.
• Undertake a continuous review of assurance information from existing suppliers and partners and follow up where relevant.
• Have included a specific item relating to the Modern Slavery Act in the agenda of contract management meetings with suppliers, enabling us to be kept informed of and monitor any changes.
• Include appropriate terms in our contractual documentation with suppliers:
  • Obliging suppliers and their contractors, suppliers and employees to comply with the Modern Slavery Act.
  • Reserving the right for Acquired Limited to audit suppliers and their contractors, where we consider it appropriate.
  • Obliging suppliers to report to us if they are aware of or suspect slavery or human trafficking in a supply chain connected to any Acquired Limited contracts.
  • Reserving the right for us to terminate the contract at any time should any instances of modern slavery come to light.
• The Procurement Team follows the advice and guidance in relation to the Modern Slavery Act set out in the Chartered Institute of Purchasing and Supply (CIPS) code of professional conduct.

The above procedures are designed to:

• Identify and assess potential risk areas in our business and supply chains.
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
• Monitor potential risk areas in our business and supply chains.

Training

We regularly conduct modern slavery training for our procurement teams and issue guidance to our employees so that they are aware of the issues surrounding modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• Reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
• The use of grievance mechanisms.
• The level of communication and personal contact with the next link in the supply chain.
• The completion of audits.

Approval for this statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Acquired Limited's slavery and human trafficking statement for the financial year ending 30 March 2019.

This statement was approved by the Board of Directors on 30 March 2019.