Modern Slavery Policy

1. Scope

This Modern Slavery and Human Trafficking Policy (“Policy”) applies to all persons working for or on behalf of Pametan Ltd (“Pametan”, “we”, “us”) in any capacity, including employees at all levels, directors, officers, contractors, secondees, agency workers, casual workers and any third parties who supply goods or services to us.

It also sets out the standards we expect from our suppliers, sub-contractors and other business partners.

“Modern slavery” is used in this Policy as a shorthand for the offences of slavery, servitude, forced or compulsory labour and human trafficking as defined in the Modern Slavery Act 2015 (UK) and equivalent offences under federal and state law in the United States (including the Trafficking Victims Protection Act) and the Criminal Code of Canada.

2. Our business

Pametan Ltd is a private limited company registered in England and Wales (Company No. 16023621) with its registered office at 20 Wenlock Road, London, England, N1 7GU.

We are a specialist fintech and regulatory technology development agency. We design, build and operate software for regulated companies — banks, lenders, brokers, payment companies and regtech platforms — across the United Kingdom, the United States and Canada.

Our work is technology services. We do not manufacture, transport or import physical goods. Our team is small, knowledge-led and almost entirely office- or remote-based. As a result, our direct exposure to high-risk modern-slavery sectors (agriculture, construction, manufacturing, hospitality, fishing) is low. Our exposure exists primarily through our supply chain — the third parties from whom we buy hardware, hosting, professional services and office support.

3. Our commitment

Pametan is fully committed to acting ethically and with integrity in all our business dealings and relationships. Specifically, we commit to:

• maintain a zero-tolerance approach to slavery, servitude, forced or compulsory labour and human trafficking in our business and supply chain;
• operate effective systems and controls to ensure modern slavery is not taking place anywhere in our operations or in those of our suppliers and partners;
• treat our employees, contractors and partners with fairness and dignity, regardless of their location, role or background;
• uphold the fundamental principles of the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work; and
• improve our practices over time as our business grows and as the regulatory and best-practice landscape evolves.

4. Risk assessment

We have assessed the modern-slavery risk profile of our business as low, on the basis of the factors set out below. We review this assessment annually and after any material change to our operations or supply chain.

4.1 Lower-risk areas

• Our workforce. Pametan employs experienced, professional engineers, designers and product staff in the UK, US and Canada. We pay above-market rates, offer permanent employment contracts where appropriate, and recruit through transparent processes.
• Our services. We deliver software development and consulting. There is no physical production, no field labour and no transportation of goods.
• Our clients. Our clients are themselves regulated financial-services entities subject to extensive controls.

4.2 Higher-risk areas (relative)

• Hardware suppliers. Laptops, monitors and peripherals are manufactured in global supply chains where labour-rights issues are documented. We mitigate this by buying primarily from major manufacturers (Apple, Dell, Lenovo) who publish their own modern-slavery statements and audited supplier data.
• Cloud and infrastructure providers. Data-centre operators and connectivity providers operate construction and facilities-management services where indirect modern-slavery risk exists.
• Office services. Cleaning, catering and security services are recognised higher-risk sectors. We use serviced office providers and select suppliers who can evidence their own modern-slavery compliance.
• Sub-contracted talent. Where we engage individual contractors or freelance specialists, the contracting itself can sit in jurisdictions with weaker labour protections. We address this through our supplier requirements (see Section 5).

5. Supply chain due diligence

We require all suppliers to comply with the principles set out in this Policy. Specifically:

5.1 Supplier requirements

• Code of conduct. All material suppliers (those with annual spend above £10,000 or who provide labour-intensive services) are required to read and acknowledge our Supplier Code of Conduct, which incorporates the principles in this Policy by reference.
• Modern slavery statement. Where a supplier is required by law to publish a modern slavery statement, we expect to see it before engagement and at each annual review.
• Contractual provisions. Our standard supplier agreement includes a warranty that the supplier and its supply chain comply with applicable modern-slavery and labour laws, and a right to terminate for breach.
• Right to audit. We reserve the right to audit material suppliers’ modern-slavery compliance, either directly or through an independent third party.

5.2 Supplier categories

6. Our people

We are committed to ensuring that everyone who works for Pametan is treated with dignity, paid fairly and freely chooses to be in their role.

• Recruitment. We recruit through reputable channels, conduct identity and right-to-work checks for every hire, and never charge applicants any kind of “recruitment fee”.
• Pay. We pay at or above the relevant Real Living Wage in the UK, market-competitive rates in the US and Canada, and on time without unauthorised deductions.
• Hours and freedom. Working hours follow local statutory limits. Employees are free to leave their employment in line with their notice period. Identity documents are never retained as a condition of employment.
• Grievance. All employees have a confidential grievance route through their line manager and, where appropriate, directly to the Founder & CEO.

7. Training and awareness

To ensure a consistent understanding of modern slavery risk, we:

• provide modern-slavery awareness training to all new joiners as part of induction;
• refresh that training annually for staff involved in supplier selection, procurement or recruitment;
• maintain a short internal guide explaining the indicators of modern slavery and the reporting routes available; and
• periodically share regulator and NGO publications (e.g. from the UK Home Office, the US State Department’s TIP Report and Polaris Project) with relevant teams.

8. Reporting concerns

Anyone with a concern about actual or suspected modern slavery in our business or supply chain should report it as soon as possible. If you wish to remain anonymous, the external authorities listed below all accept anonymous reports without requiring identification.

Reports may be made:

• Internally: by email to ethics@pametan.co, which is monitored by the Founder & CEO; or in person to any member of the leadership team.
• Externally (UK): to the Modern Slavery and Exploitation Helpline on 08000 121 700, or to the police on 999 in an emergency or 101 otherwise.
• Externally (US): to the National Human Trafficking Hotline on 1-888-373-7888.
• Externally (Canada): to the Canadian Human Trafficking Hotline on 1-833-900-1010.

All internal reports are treated in confidence and are protected under the principles of our Whistleblowing Policy. No employee will be subject to detrimental treatment for raising a genuine concern.

9. Governance

Responsibility for this Policy rests with the Founder & CEO of Pametan Ltd. Day-to-day responsibility for embedding it in our recruitment, procurement and operational practices is shared across the leadership team.

The Founder & CEO will report annually to the board on:

• the outcome of the annual risk assessment;
• any material changes to our supply chain or supplier list;
• any concerns raised through the reporting channels in Section 8 and the response taken; and
• training delivered and outstanding actions for the year ahead.

10. Review

This Policy will be reviewed at least annually, and sooner if there is a material change in our business, supply chain or applicable law. The version number, “last updated” date and effective date at the top of this document reflect the most recent revision.

Where this Policy doubles as our voluntary modern-slavery statementfor a financial year, that fact will be noted on this page along with board-approval details. Once Pametan’s annual turnover exceeds £36 million, we will publish a separate statutory statement under section 54 of the Modern Slavery Act 2015 in addition to maintaining this Policy.

11. Approval

This Policy was approved by the Board of Directors of Pametan Ltd and signed on behalf of the company by:

12. Contact

For questions about this Policy, or to report a concern as set out in Section 8:

• Email: ethics@pametan.co
• Post: Founder & CEO, Pametan Ltd, 20 Wenlock Road, London N1 7GU, United Kingdom