1. Purpose of this Policy

Modern slavery is a crime and a grave violation of fundamental human rights. It can take many forms, including slavery, servitude, forced or compulsory labour, and human trafficking. All involve depriving a person of their liberty for personal or commercial gain.

Payday Cloud has a zero-tolerance approach to modern slavery. We are committed to conducting our business ethically, with integrity, and in full compliance with applicable laws. We strive to ensure modern slavery and human trafficking are not present in our operations or supply chains.

2. Scope

This policy applies to all individuals working for or on behalf of Payday Cloud in any capacity. This includes employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, contractors, external consultants, third-party representatives, and business partners.

3. Responsibilities

  • Management at all levels are responsible for ensuring their teams understand and comply with this policy. They must also ensure employees receive adequate and regular training on modern slavery and ethical practices in supply chains.
  • All employees and representatives are required to read, understand, and comply with this policy and report any concerns promptly.

4. Our Commitments

We are committed to upholding the following principles in our business and supply chains:

  • Employment must be freely chosen.
  • Freedom of association must be respected.
  • Working conditions must be safe and hygienic.
  • Child labour must never be used.
  • Fair wages must be paid.
  • Working hours must not be excessive.
  • Discrimination must not be practised.
  • Regular and secure employment must be provided.
  • Harsh or inhumane treatment must not be permitted.
  • Accommodation standards, where provided, must meet health and safety requirements.
  • The rights of home-based, agency, and migrant workers must be respected.
  • All business must be conducted lawfully, fairly, and to a high ethical standard.

5. Compliance and Reporting

  • Preventing, detecting, and reporting modern slavery in any part of our business or supply chains is everyone’s responsibility.
  • Employees must avoid any activity that might breach this policy or appear to do so.
  • If you believe or suspect a breach of this policy has occurred or may occur, you must report it immediately to your manager, the Compliance Manager, or in line with Payday Cloud’s Whistleblowing Policy.
  • Concerns should be raised as early as possible. If in doubt, raise it.

Payday Cloud is committed to protecting those who report concerns in good faith. No employee or individual will suffer detrimental treatment—such as dismissal, disciplinary action, threats, or other unfavourable outcomes—for reporting suspicions of modern slavery.

If you believe you have been treated unfairly as a result of raising a concern, you should inform the Compliance Manager immediately. Employees may escalate unresolved matters through the Grievance Procedure.

6. Breaches of this Policy

• Employees who breach this policy may face disciplinary action, up to and including dismissal for misconduct or gross misconduct.

• We may terminate relationships with contractors, suppliers, or other third parties if they are found to be in breach of this policy.

7. Continuous Improvement

We will regularly review and update this policy to ensure it remains effective, relevant, and aligned with legal and ethical standards. We welcome feedback and suggestions for improvement, which should be directed to your manager or the Compliance Manager.

Approved by: The Board of Directors

Date: 29.08.25

Review Date: 1.09.26