INTRODUCTION
Modern slavery and human trafficking are crimes and fundamental violations of human rights. Taptap Send has a zero tolerance approach to both of them.
Taptap Send is committed to treating everyone with dignity and respect and to improving its practices to combat slavery and human trafficking, to ensure that they are not taking place in any part of its business or its supply chains. Taptap Send expects the same commitment from all of its suppliers, contractors, partners and other stakeholders. In this statement, Taptap Send sets out the steps taken to achieve that goal. Information for this statement was gathered through Taptap Send’s annual supply chain review, drawing on input from the legal and compliance functions.
The term “Taptap Send” as used in this statement refers collectively to Taptap Send, Inc. (the parent company) and its subsidiaries, including Taptap Send UK Limited, whose financial year ended on 31 December 2025. This statement is made on behalf of Taptap Send UK Limited pursuant to section 54(1) of the UK Modern Slavery Act 2015, but applies to every company in the Taptap Send group. This statement was approved by the Board of Directors of Taptap Send UK Limited on 26 March 2026.
OUR BUSINESS AND ORGANISATIONAL STRUCTURE
Taptap Send is a leading international money transfer business enabling customers in the United States, Canada, the United Kingdom, the United Arab Emirates, Australia, New Zealand and the European Economic Area to send remittances to recipients in more than 70 countries in Africa, Asia, the Caribbean and Latin America.
Taptap Send has considered whether its business model and commercial practices may cause or contribute to modern slavery risk. As a digital financial services business, Taptap Send’s primary supply chain consists of technology and professional services. Taptap Send also procures physical payment cards for its prepaid card product in the UK and European Economic Area, involving card manufacturing, personalisation and fulfilment services. Taptap Send does not engage in the high-volume manufacturing or agricultural procurement practices (including aggressive pricing pressure, short lead-time ordering, and opaque multi-tier subcontracting), most closely associated with forced labour risk.
Taptap Send’s founding mission is to lower the cost of international remittances to below 3% of transfer value, in line with UN Sustainable Development Goal 10c. This mission directly supports the financial agency and economic independence of migrant workers, who are among the populations most vulnerable to labour exploitation and trafficking. None of the work done by Taptap Send is seasonal, nor does it relate to those sectors which are considered to have a higher risk of modern slavery (e.g. construction, food and drink, agriculture, mining and retail). Taptap Send does not consider its business model to create structural incentives that could cause or contribute to modern slavery.
OUR VALUES AND POLICIES ON SLAVERY AND HUMAN TRAFFICKING
Taptap Send is committed to fighting modern slavery and human trafficking by acting ethically and with integrity in all its business relationships and by implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in its business and supply chains.
Taptap Send’s policies and procedures, including the Code of Conduct and the Anti-slavery and Human Trafficking Policy, reinforce this commitment. Taptap Send employees, consultants and other workers at all levels are required to report any suspected illegal or unethical conduct so it can be further investigated. Taptap Send’s Anti-slavery and Human Trafficking Policy specifically prohibits the use of forced, compulsory or trafficked labour, child labour, and any form of worker exploitation.
Taptap Send’s employment practices reflect fundamental labour standards. All workers are free to terminate their employment in accordance with their contractual notice period, without penalty. Taptap Send does not restrict the freedom of movement of its staff, does not impose compulsory overtime, and does not confiscate or retain original identity documents. No fee is charged to job applicants at any stage of recruitment, inline with the Employer Pays Principle. Taptap Send respects the right of its staff to freedom of association and collective bargaining in accordance with applicable law. Taptap Send’s Code of Conduct expressly prohibits threats of violence, harassment and intimidation in the workplace, and any such conduct is subject to disciplinary action. The Code of Conduct also requires all Taptap Send staff to comply with applicable laws and regulations, to maintain ethical standards (especially when dealing with partners and stakeholders) and to act with honesty, respect, integrity and transparency.
Taptap Send’s approach to policies in this area is informed by the UN Guiding Principles on Business and Human Rights and relevant ILO labour standards. These policies are communicated to all staff at onboarding and are reinforced through mandatory annual training. The compliance function is responsible for monitoring adherence, and policy breaches are subject to Taptap Send’s disciplinary procedures.
OUR SUPPLY CHAINS
Taptap Send’s supply chains involve a range of different institutions and businesses around the world, which provide support in areas such as financial services, telecommunications, recruitment, compliance, technology, legal and banking. These suppliers are primarily based in Taptap Send’s operating markets (including the United Kingdom, European Economic Area, United States, Canada, United Arab Emirates, Australia and New Zealand) as well as in the destination countries to which Taptap Send disburses funds across Africa, Asia, the Caribbean and Latin America. Taptap Send’s principal suppliers are:
- Technology and infrastructure providers;
- Payment processors;
- Financial institutions;
- Compliance service providers; and
- Business process outsourcers.
Taptap Send also procures operational support services including facilities management and office services, which are assessed as lower risk given the nature of Taptap Send’s business.
Taptap Send is committed to ensuring that slavery or human trafficking do not take place within its supply chains and it will not knowingly support or do business with any organisation which is involved in or could be associated with such practices. In the event of any modern slavery or human trafficking finding or suspicion arising in respect of an existing relationship, Taptap Send would seek first to understand the nature and extent of the issue and, where possible, work with the relevant party to remediate the concern. Disengagement from a relationship would be considered a last resort where such remediation has failed or is not possible. Furthermore, Taptap Send will cooperate fully with any relevant law enforcement, statutory or judicial process arising from such finding or suspicion.
All suppliers are subject to screening by Taptap Send to ensure they reflect Taptap Send’s values and are suitable business partners. Taptap Send is also committed to ensuring that all partners hold themselves to the same high standards that Taptap Send sets itself.
OUR DUE DILIGENCE PROCESSES
Taptap Send has in place a dedicated compliance team, supported by its legal function and auditors and maintains processes to identify and assess potential areas of risk within the organisation and its supply chains.
These involve carrying out due diligence on suppliers and partners to understand their own processes and get comfortable that they align with Taptap Send’s values. All contracts that Taptap Send enters into require third parties to confirm compliance with all applicable laws and regulations. Taptap Send employees and workers are able to report concerns about suspected modern slavery or unethical conduct through Taptap Send’s internal reporting channels, including its confidential whistleblowing mechanism. Where concerns are identified within the supply chain, Taptap Send will engage directly with the relevant partner to investigate and, where appropriate, require and support remediation. Taptap Send’s remediation approach prioritises the welfare of affected workers, consistent with a victim-centred framework.
Tackling modern slavery means understanding the entire supply chain beyond the companies Taptap Send directly contracts with. Taptap Send expects both its direct and indirect supply chain to uphold the same ethical principles as Taptap Send and to implement these through appropriate (i) due diligence procedures on their suppliers and (ii) grievance and disclosure mechanisms for their own workers.
RISK ASSESSMENT AND EFFECTIVENESS
On an annual basis, Taptap Send carries out a risk assessment for each regulated entity in its group. As part of this process, the supply chain of modern slavery and human trafficking risk is considered as one of the factors contributing to the wider assessment. Taptap Send’s assessment draws on publicly available risk data (including, for example, the Global Slavery Index) alongside a review of supplier due diligence findings, analysis of operating geographies, and consideration of any concerns raised through internal reporting mechanisms. An effectiveness review will also be conducted by Taptap Send as part of its annual audit of compliance policies and procedures. This assessment is led by Taptap Send’s Head of Financial Crime, with oversight from the Board of Directors. Taptap Send has assessed its own direct operations as lower risk given the nature of its business (digital financial services) and the regulatory environments in which it operates. No incidents of modern slavery were identified during the period covered by this statement.
Taptap Send’s goal for the coming year is to strengthen its supplier risk assessment methodology and to set measurable key performance indicators (KPIs) for its modern slavery programme, to be reported in future statements.
TRAINING
Taptap Send provides training on modern slavery and human trafficking to all of its employees and workers. This sits alongside other mandatory compliance training (e.g. on financial crime). The training covers how to recognise indicators of modern slavery and forced labour, Taptap Send’s reporting obligations and internal escalation procedures, and relevant legal requirements under the Modern Slavery Act 2015. Training is delivered through Taptap Send’s online learning platform and is completed annually by all staff, as well as by all new joiners as part of their onboarding. 100% of Taptap Send staff completed the mandatory training in 2025. The training materials are reviewed annually.
YEAR-ON-YEAR IMPROVEMENT
Since the previous statement, Taptap Send has expanded the number of countries from which it operates originating transfers (adding New Zealand) and significantly grown the number of receiving markets to over 70 countries, bringing a greater range of supply chain relationships within scope.
Looking ahead, Taptap Send's modern slavery improvement work in 2026 will focus on four priorities:
- formalising its supply chain mapping through a structured review of its supplier base;
- consolidating its supplier compliance requirements into a formal Supplier Code of Conduct;
- developing and publishing a suite of outcome-focused KPIs for the modern slavery programme, including training completion rates, supplier assessment coverage and grievance reporting metrics; and
- building a programme of external engagement with suppliers, relevant industry bodies and civil society organisations to strengthen its risk assessment and monitoring processes.
Signed by: Michael Faye
Title: Director
Date: 26 March 2026