Modern Slavery Statement

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.

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 2021. 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 14 January 2022.


OUR BUSINESS AND ORGANISATIONAL STRUCTURE

Taptap Send is a leading international money transfer business enabling customers in the
United States, Canada, the United Kingdom and the European Economic Area to send
remittances to recipients in more than 15 countries in Africa and Asia.

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, resource
and mining and retail).


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 encouraged to report any suspected illegal or unethical conduct
so it can be further investigated. The Code of Conduct 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.


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.

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 suspicion arising in respect of an existing relationship, Taptap Send would
seek to terminate the same immediately.

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 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.

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 it.


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 modern slavery and human trafficking risk is
considered as one of the factors contributing to the wider assessment. An effectiveness review
will also be conducted by Taptap Send as part of its annual audit of compliance policies and
procedures.


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).
Looking ahead, Taptap Send is committed to strengthening its processes and raising awareness
of this issue, by making sure its employees and workers are well equipped and trained to
identify modern slavery and human trafficking (whether in the workplace or in third parties).


Signed by: Mitchell Riley
Title: Director
Date: 14 January 2022