PayFarGo

Legal

Modern Slavery Statement

Our approach to preventing modern slavery, forced labour, and human trafficking in our operations and supply chains.

This Modern Slavery and Human Trafficking Statement ("Statement") is issued by PayFarGo ("the Company," "we," "our," or "us"). It sets out our approach to dealing with the potential risk of slavery and human trafficking at PayFarGo, as well as within our supply chains.

This Statement outlines the steps we have taken and continue to take to prevent modern slavery, forced labour, servitude, child labour, and human trafficking within our business operations and supply chains. While the United States does not currently maintain a single consolidated federal "Modern Slavery Act," this Statement is prepared in alignment with applicable United States federal laws prohibiting forced labour and human trafficking, including the Trafficking Victims Protection Act ("TVPA"), the Tariff Act of 1930 (as amended), the California Transparency in Supply Chains Act of 2010 where applicable, and internationally recognised human rights principles and standards.

Introduction

PayFarGo is committed to conducting business ethically, responsibly, and with integrity. We recognise our responsibility to respect and uphold human rights throughout our operations and supply chain and maintain a zero-tolerance approach to modern slavery and human trafficking in any form.

We are committed to implementing effective systems, controls, and governance measures designed to identify, assess, mitigate, and address the risk of forced labour, involuntary servitude, child labour, and human trafficking within our organisation and among our third-party business relationships.

Our Business

PayFarGo is a United States-based digital remittance and financial technology company providing international money transfer and payment services to customers across multiple jurisdictions worldwide.

Our services enable individuals and businesses to send and receive cross-border payments through digital channels, banking networks, mobile wallet integrations, and payment settlement infrastructure. We operate through relationships with financial institutions, payment processors, technology vendors, telecommunications providers, compliance service providers, cloud infrastructure providers, and other operational partners.

Our principal office is located in the United States, and our operations are conducted in compliance with applicable financial services, anti-money laundering, sanctions, and consumer protection laws and regulations.

Our Commitment to Human Rights and Ethical Conduct

We are committed to maintaining ethical business practices and fostering a culture of accountability, transparency, and compliance.

Our commitment against modern slavery and human trafficking is supported by our internal policies and governance framework, including:

  • Code of Business Conduct and Ethics;
  • Whistleblower and Non-Retaliation Policy;
  • Anti-Bribery and Anti-Corruption Policy;
  • Vendor and Third-Party Risk Management Procedures;
  • Equal Employment Opportunity and Workplace Standards Policies;
  • Anti-Money Laundering and Financial Crime Compliance Policies.

These policies establish expectations for lawful and ethical conduct across our organization and require employees, contractors, consultants, and third-party representatives to comply with applicable laws relating to labour standards, anti-trafficking protections, and human rights. Employees and stakeholders are encouraged to report suspected misconduct, unethical practices, or potential human rights violations through designated reporting channels without fear of retaliation.

Supply Chain and Third-Party Relationships

Our supply chain and operational ecosystem include domestic and international third-party providers and partners, including:

  • Financial institutions and banking partners;
  • Payment processors and remittance settlement providers;
  • Cloud computing and technology infrastructure providers;
  • Telecommunications and mobile network operators;
  • Customer support and outsourcing service providers;
  • Identity verification and compliance vendors;
  • Professional services firms and consultants.

We recognize that certain industries and jurisdictions may present heightened risks relating to labour exploitation and human trafficking. Accordingly, we apply a risk-based approach to supplier onboarding, due diligence, and ongoing monitoring.

Due Diligence and Risk Mitigation

As part of our customer management and compliance processes, we may undertake reasonable and proportionate due diligence measures, including:

  • Know-your-customer (KYC) verification;
  • Know-your-business (KYB) verification;
  • Regulatory licensing and registration checks;
  • Sanctions and adverse media screening;
  • Assessment of supplier compliance practices and governance standards;
  • Review of contractual commitments regarding compliance with applicable labour and anti-trafficking laws;
  • Risk-based assessments of suppliers operating in higher-risk jurisdictions or sectors.

We do not knowingly engage with or support any entity involved in forced labour, human trafficking, child labour, or exploitative labour practices. Where credible evidence of such conduct is identified, we reserve the right to suspend or terminate the applicable business relationship and take any further remedial action deemed appropriate.

Internal Accountability and Training

We recognize that awareness and accountability are essential components of effective anti-slavery compliance.

Relevant personnel, particularly employees involved in compliance, procurement, operations, legal, human resources, and vendor management functions, may receive training or guidance relating to:

  • Human rights and modern slavery risks;
  • Ethical sourcing and vendor management;
  • Whistleblower reporting procedures;
  • Identification and escalation of suspicious or unethical conduct;
  • Compliance obligations relating to anti-trafficking and labour standards.

We continue to review and strengthen our compliance framework and employee awareness initiatives as our operations expand.

Monitoring and Continuous Improvement

We are committed to continuously improving our policies, procedures, and oversight mechanisms relating to modern slavery prevention and ethical business conduct.

Our ongoing efforts may include:

  • Periodic review of supplier risk management procedures;
  • Enhancement of contractual compliance requirements;
  • Monitoring emerging regulatory developments and best practices;
  • Reviewing and updating internal policies and training programs where appropriate.

Board Approval

This Statement has been reviewed and approved by the Board of Directors of PayFarGo and reflects our ongoing commitment to ethical business operations and responsible supply chain management.

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