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Modern Slavery Act


This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Luxon Pay and relevant group companies (“Luxon Pay”) during the year ended 31 December 2020 to prevent modern slavery and human trafficking in its business and supply chains. Luxon Pay is committed to ensuring that our business has no involvement in modern slavery or human trafficking. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Luxon Pay will not support or deal with any business knowingly involved in modern slavery or human trafficking.

Our business and structure

Luxon Pay is fully regulated by the FCA leading global provider of end-to-end payment solutions. Our core purpose is to enable our users to connect and transact seamlessly through industry-leading capabilities in payment processing, digital wallet, and card issuing. Luxon Pay has approximately 100 employees, who are primarily based in office locations across the United Kingdom. We do not employ significant numbers of temporary or agency staff.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or in our supply chains. We have a Global Conduct Policy in place signed off at director level, which applies to all employees across Luxon Pay, to reflect and enforce our commitment to conduct all our business in an honest and ethical manner. This includes our anti-slavery and human trafficking policy, to implement and enforce systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business.

Risk Assessement

During 2020 we have continued to assess our business and supply chains to identify any particular sectors or geographies where a greater risk of modern slavery or human trafficking may occur and have sought to identify what measures are in place to mitigate those risks. For example:
  • our contracts with suppliers for the provision of cleaning services to our UK offices require the suppliers to comply with all applicable legislation and to meet all regulatory and industry standards in providing the services, and to ensure that sufficient resources are allocated to properly provide the services; and
  • when we procure Luxon Pay-branded promotional merchandise, this is sourced from a supplier which is a member of the Ethical Trading Initiative and Sedex (the Supplier Ethical Data Exchange).

Training and compliance

All Luxon Pay employees are required to read, understand and commit to follow our Global Conduct Policy. Members of senior management receive specific face-to-face training on our Global Conduct Policy in order to promote the policy throughout our organisation.


Our global Compliance Policy includes detailed whistleblowing procedures to enable and encourage employees to express concerns regarding any misconduct or wrongdoing related to our business. This may be done either by raising a concern internally, or anonymously through our external whistleblowing channel. All reports will be investigated and appropriate remedial actions taken. All employees are required to periodically complete an online training module which highlights these procedures. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Luxon Pay slavery and human trafficking statement for the financial year ended 31 December 2019. This statement has been approved by the board of directors of Luxon Pay.