UK Modern Slavery and Human Trafficking Statement.

1. Introduction

Olympus Pay Limited opposes modern slavery and human trafficking in every form. They are serious violations of human rights.

This is our first statement. We began our modern slavery programme in 2026, so we have no earlier statements and no history to report. We have written this as we go: it describes what we are putting in place and what we intend to do, and it does not claim results we have not yet achieved. We will report on our progress in next year’s statement.

It is made with reference to section 54(1) of the UK Modern Slavery Act 2015.

2. Our structure

Olympus Pay Limited is a company registered in England and Wales (number 16132811), with its registered office at 14/2E Docklands Business Centre, 10-16 Tiller Road, London, United Kingdom, E14 8PX. It is part of the Olympus group, owned by Olympus Group Holdings, Inc.. The group also operates in Botswana through Olympus Pay Proprietary Limited.

3. Our business

We are a financial technology company. We serve businesses with digital payments, multi-currency products, fraud prevention and risk management, and banking services delivered with regulated partners. Regulated services in the United Kingdom are provided through Gemba Finance Limited, which is authorised and regulated by the Financial Conduct Authority.

4. Our supply chain

We buy:

• technology and infrastructure services, such as cloud hosting, identity verification, messaging and monitoring
• professional and outsourced services, including legal, accounting and compliance support
• recruitment and contract labour
• office and facilities services

We also work with regulated and payment partners, who are subject to their own regulation and to their own obligations under the Act.

5. Our commitment

We have a zero-tolerance approach to modern slavery, forced labour and human trafficking. We are committed to fair labour practices across our operations and partnerships, careful due diligence on suppliers and other third parties, compliance with the UK Modern Slavery Act 2015, training our people to recognise and report concerns, and improving as we learn. We expect the same standards from our suppliers, business partners and service providers, and where we find a breach we will act, which can include ending the relationship.

6. What we are putting in place

Our programme rests on four policies, which we are introducing this year:

• Modern Slavery and Human Rights Policy. Our commitment to preventing forced labour and ensuring fair working conditions. It applies to our employees, suppliers, contractors and business partners.
• Whistleblowing and Ethical Reporting Policy. We want employees and third parties to speak up about unethical behaviour, including modern slavery. Concerns can be reported anonymously, and people who report in good faith will be protected from retaliation. Reports will be investigated.
• Third-Party Risk Management Policy. Suppliers, vendors and outsourcing partners are to be screened and risk-assessed before we work with them, must meet our compliance requirements, and are to be monitored afterwards.
• Recruitment and employment practices. Our employees are to be legally entitled to work where they are based, receive fair pay and benefits, work in safe conditions and be protected from discrimination and exploitation. Recruitment agencies we use must meet the same standards.

7. Due diligence

We are setting up a due diligence process for suppliers and partners. Before we work with one, we will screen it and assess the risk. We will onboard it with compliance requirements, and after that we will monitor it and review the relationship if concerns arise.

8. Where we see the most risk

For a business like ours, the areas that carry the most risk are recruitment and contract labour, and outsourced and facilities services. We will focus our first checks there. Our financial crime compliance team also watches for transactions in our payment systems that may be linked to human trafficking.

9. Training

We are introducing training on modern slavery. It is intended for all employees, including leadership and compliance teams, and for recruitment agencies, HR teams, and suppliers and service providers where relevant. It will cover how to identify risks, how to report suspicious activity, and legal and ethical responsibilities under the Act.

10. How we will check it works

From this year we intend to carry out:

• an annual modern slavery risk assessment
• checks on our suppliers
• a review of any whistleblowing cases, to spot new risks

We will publish what we find, and what we change, in our next statement.

11. Reporting a concern

Employees, suppliers and members of the public can raise a concern with us at legal@olympuspay.co. You can also call the UK Modern Slavery Helpline on 08000 121 700, or read more on the helpline website. If someone is in immediate danger, call the police on 999.

12. Looking ahead

Next year’s statement will report what we have done: the policies in force, who has been trained, what our risk assessment and supplier checks found, and what we will do next. We will review this statement every year.