Modern Slavery Statement

Statement from the board

This Modern Slavery and Human Trafficking Statement is prepared following Section 54, Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31st of March 2023.

SumUp Payments Limited is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, its products and its customer base. We have zero tolerance towards slavery and require our supply chain to comply with our values. 

In line with SumUp’s obligations as a Financial Conduct Authority (FCA) regulated financial institution, as well as SumUp’s commitment to the highest ethical standards, we screen our clients, suppliers, and partners to help ensure that we do not directly or indirectly support or facilitate any form of coercion, slavery or human trafficking.

SumUp will continue to take all reasonable steps to ensure all employees, agents, and providers within SumUp’s supply chains are not subject to any form of forced, compulsory/bonded labour or human trafficking. 

SumUp’s Executive team takes responsibility and accountability for implementing this Statement and makes certain that resources are made available to ensure slavery and human trafficking are not taking place within SumUp’s company or, to the best of our knowledge, within SumUp’s supply chains and customers. 

Suppliers are assessed for compliance with the Modern Slavery Act prior to entering a relationship with SumUp. Senior Management is responsible for monitoring the individual supplier relationships and will monitor the control framework required over the supplier on an ongoing basis having regard to process, escalation and incident management.

SumUp’s Compliance, AML, and Onboarding teams will continue to ensure that all customers are screened in line with local operational procedures and apply further Due Diligence when appropriate. Our Head of Compliance will report annually on our compliance with the Act to the Board of Directors.

This Statement and associated documentation will be reviewed annually prior to SumUp publishing its annual audit Financial Statements (incorporating Modern Slavery Act requirements) to Companies House.

1.0 What constitutes slavery and human trafficking

1.1 Slavery 

Slavery is when a person is held as a slave, or servitude equivalent to slavery, or is required to perform forced or compulsory labour. Slavery, servitude and/or compulsory labour shall be construed as follows: “No one shall be held in slavery or servitude; slavery and the slave trade shall be prohibited in all their forms”.

In determining whether a person is being held in slavery or servitude or required to perform forced or compulsory labour, regard may be had to all the circumstances. Such circumstances can be in case of a child, the person’s family relationships, and any mental or physical illnesses which may make a person more vulnerable. Considerations must be made to any work or services provided in circumstances which may constitute exploitation.

Any consent obtained, whether from an adult or a child or a vulnerable person, cannot preclude a determination that a person is a victim of slavery or exploitation.

1.2 Human trafficking

Human trafficking, or trafficking in persons, occurs when a person or group arranges or facilitates the travel of another person or persons with an intention for exploitation or with the knowledge or suspicion that another person will be exploited.

It can involve physical movement but does not have to involve movement to another country.

'Exploitation' in these cases can include but is not limited to including slavery, forced labour, debt bondage, sexual exploitation, harvesting of organs or forced marriage.

In cases of exploitation concerning children or vulnerable persons, any 'consent' given by parents/guardians is considered invalid as it cannot be granted or enforced for illegal action.

2.0 SumUp’s area of operations

SumUp Payments Limited is an Authorised Electronic Money Institution regulated by the Financial Conduct Authority and complies with all the laws and regulations imposed on the EMIs. 

SumUp Payments Limited operates in the United Kingdom and Switzerland. 

3.0 Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

This includes the following: 

  • Anti-Money Laundering and Counter Terrorism Financing Policy

  • Sanctions Policy

  • Know Your Customer Policy

  • Third Party and Outsourcing Policy

  • Product Oversight and Governance Policy

  • Operational Risk Policy

  • Product Oversight and Governance Policy

  • SumUp Payments Limited Code of Conduct

  • Whistleblowing Policy

We make sure that SumUp’s suppliers are aware of SumUp’s policies and adhere to the same standards. 

4.0 Employees

SumUp’s Values and Culture and SumUp’s Code of Conduct outline that we are committed to respect human rights in the workplace. SumUp requires that all SumUp employees treat colleagues with dignity and respect, creating an inclusive environment. We do not tolerate any discrimination, bullying, or harassment on any ground.  We encourage employees to speak up against any infringement on their rights or discrimination. We encourage managers to have a regular meeting with the employees where there is no agenda, other than discussing work relationship, progress, and development. During such meetings our employees can raise any issues or concerns. We understand that some of the employees may not feel comfortable to speak up during such sessions, especially if the concerns relate to their line manager. For such circumstances, SumUp has a  Whistleblowing Policy. 

SumUp annually surveys its employees and how they feel about working at the company. The survey is anonymised and through this we are getting a general understanding of how we are meeting SumUp’s obligations and expectations.

SumUp respects employee freedom of association and is open to work with the employee representative bodies if SumUp’s employees wish so. SumUp recognizes that employees have a right to be treated with dignity and respect and in accordance with their service conditions and policies.

SumUp ensures that all its employees are paid fairly and expects the same from its suppliers. SumUp’s pay policy is designed to pay our people fairly, to attract, retain and motivate the best people, regardless of gender, ethnicity, age, disability or any other factor unrelated to performance or experience. 

As a financial institution, SumUp has implemented employee screening procedures, which includes, where legally permissible,  background checks for all new employees and contractors. In addition, as part of SumUp’s hiring process, we have instituted a bar raiser interview, where applicants are assessed on their  character and compatibility with SumUp’s values. This enables SumUp to confirm the candidate's identity, employment history,qualifications, and test their integrity in accordance with SumUp’s values, confirming there are no legal or regulatory barriers to employing them. It also validates that new joiners have the right to work in the UK and that they have no recorded criminal associations. 

5.0 Suppliers

SumUp expects its suppliers to respect human rights and adhere to anti-slavery and human trafficking statements as it is outlined in the Article 4 of the Universal Declaration of Human Rights and in the UK Modern Slavery Act 2015

Suppliers, if they are outside of the UK, must comply with all relevant legislation, regulations and directives in their respective countries, and with the requirements of the SumUp’s standards, where these go further and do not conflict with local law.

SumUp unequivocally prohibits the use of child labour, forced labour, servitude, dept bondage or a compulsory labour. SumUp requires its suppliers to respect labour rights, the right to freedom of association and have a non-discriminatory position. 

SumUp categorically prohibits any involvement in human trafficking or relocation under duress. Workers, whether local or migrant, must have the right and ability to leave employment when they choose and a contractually outlined notice period should not be used as a covert tool of forced labour. 

Contracts with suppliers are carefully drafted and/or reviewed, and SumUp always maintains the right to review suppliers’ policies and arrange on-site visits and/or conduct audits of their compliance with the Modern-Day Slavery Act and/or the Universal Declaration of Human Rights. SumUp also requires suppliers to provide evidence that they have implemented due diligence procedures to manage ethical issues within their own supply chains. 

SumUp uses third parties to supply it’s goods (cards and card readers) and services. Risks arising from the use of third-party suppliers may be hard to detect. Therefore, we have implemented appropriate risk management policies, processes, and practices. These include controls over the choice, governance, and oversight of third parties.  

Before SumUp enters a business relationship with the supplier, we review the following:

  • If the supplier has human rights issues. 

  • forced labour. 

  • child labour. 

  • Health and safety issues.

  • Any form of discrimination.  

  • Employment conditions. 

  • Money laundering. 

  • Terrorism Financing.

  • Trafficking or exploiting migrant workers.

  • Bribery and Corruption. 

Each supplier at SumUp has its engagement manager, who oversees the standards and assesses risks and requirements. 

6.0 Customers

SumUp is determined to ensure that the financial services it provides to its customers do not have a negative impact on people or the environment. 

SumUp was established in 2012 and from the outset it’s aim was and still is to serve the everyday hero, which are Small and Medium-sized Enterprises (SMEs), and micro-merchants. 

SumUp’s policies on anti-money laundering and counter-terrorism financing, sanctions, KYC, onboarding, anti-bribery and corruption set out strict guidance and criteria on customer identification, verification, ongoing screening, and risk rating.

We carry out ongoing monitoring of SumUp’s customers throughout the customer life cycle and follow reporting obligations. 

SumUp is committed to protecting the financial system on which SumUp’s customers depend on SumUp, and its financial crime team is working hard to identify, mitigate and deter financial crime risks and provide valuable information to the government authorities. 

7.0 Monitoring

We conduct ongoing monitoring of SumUp’s suppliers and SumUp’s merchants to ensure that they are compliant with their contractual commitments and are delivering products or services by SumUp standards. Suppliers and merchants that present heightened risks may be subject to additional audits or reviews.