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Modern Slavery and Human Trafficking Statement

Introduction

This Modern Slavery Statement is published in accordance with Section 54(1) of the UK Modern Slavery Act 2015 (the "Act") and outlines the steps taken by Colibrix to ensure that modern slavery and human trafficking do not take place within any part of our business operations or supply chains. This statement covers the financial year ending 30 April 2024.

Our Business and Structure

Colibrix is a UK-based Payment Service Provider and licensed Electronic Money Institution (EMI, reference number 927920), fully regulated by the Financial Conduct Authority (FCA). Headquartered in London, Colibrix specializes in delivering secure and reliable payment solutions to merchants across various industries. Since 2023, Colibrix has been an official Principal Member of Mastercard, leveraging a network of trusted business partners and service providers to ensure seamless, compliant, and efficient financial services.

Our Policy and Approach

Colibrix is committed to conducting its business ethically and responsibly. We adopt a zero-tolerance approach to modern slavery and human trafficking in any form. Colibrix expects all employees, merchants, and business partners to uphold the highest ethical standards, ensuring that no modern slavery practices occur in our operations or supply chains.

To reflect this commitment, Colibrix has implemented robust internal policies and procedures designed to mitigate the risk of modern slavery within our business and relationships. These include:

  • Anti-Slavery and Human Trafficking Policy - Sets clear expectations for ethical conduct, requires due diligence on suppliers and business partners and ensures robust risk assessment, monitoring, and reporting mechanisms to prevent exploitation in our operations and supply chains.
  • Whistleblowing Policy – A confidential channel for employees to report concerns, including suspicions of unethical practices or modern slavery, without fear of reprisal.
  • AML/CFT Compliance Program – Procedures to detect, report, and prevent illicit activities, including those potentially linked to modern slavery or human trafficking.

Due Diligence and Risk Management

To ensure modern slavery and human trafficking do not occur within our operations or supply chains, Colibrix applies a risk-based approach through the following processes:

  1. Business Partner Onboarding
    • We conduct rigorous due diligence on business partners to ensure they meet our compliance standards. This includes assessing their ethical practices, reputation, and adherence to relevant legal obligations.
  2. Ongoing Monitoring
    • Colibrix maintains continuous oversight of our business partners, analyzing activities to identify and address any unusual or high-risk patterns that may also indicate potential exposure to modern slavery or human trafficking risks.

Identifying and Managing Risks

While Colibrix operates in a relatively low-risk sector, we remain vigilant in identifying and addressing potential risks. We recognize that certain areas within supply chains or partnerships may pose higher risks, and we take proactive steps to mitigate them by:

  • Partnering only with reliable and reputable merchants and service providers.
  • Monitoring emerging risks and trends through collaboration with relevant authorities and industry stakeholders.

Effectiveness and Continuous Improvement

Colibrix measures the effectiveness of its approach to modern slavery prevention through the following indicators:

  • Completion of due diligence and oversight reviews for business partners.
  • Identification and resolution of risks through ongoing monitoring.
  • Feedback from whistleblowing and reporting mechanisms.

Future Commitments

Colibrix remains dedicated to strengthening its efforts to combat modern slavery. Our ongoing initiatives include:

  • Enhancing due diligence processes to ensure higher scrutiny of new and existing business partners.
  • Strengthening collaboration with industry stakeholders and relevant authorities to share best practices and identify emerging risks.

Approval

This statement has been approved by the Board of Directors of Colibrix and reflects our ongoing commitment to ethical business practices and compliance with the Modern Slavery Act 2015 for the financial year ended 30 April 2024 and was approved for the publication on 14 October 2024.

______________________________

Andrei Zayats
Director