Modern Slavery Act Transparency Statement

Introduction

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by relevant companies within the Paysafe Group during the year ended 31 December 2025 to prevent modern slavery and human trafficking in its business and supply chains.

Paysafe is committed to ensuring that our business has no involvement in modern slavery or human trafficking. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

Paysafe will not knowingly support or deal with any business involved in modern slavery or human trafficking, and is committed to ensuring that our business has no involvement in modern slavery and human trafficking. Our commitment is aligned with the principles of the ILO Core Conventions and the UN Universal Declaration of Human Rights.

Our business and structure

Paysafe is a leading payments platform with an extensive track record of serving merchants and consumers in the global entertainment sectors. Its core purpose is to enable businesses and consumers to connect and transact seamlessly through industry-leading capabilities in payment processing, digital wallet, and online cash solutions. With 30years of payments experience, an annualized transactional volume of $152 billion in2025, and approximately 2,800 employees located in 12+ countries, Paysafe connects businesses and consumers across 260 alternative payment types in over 48 currencies around the world. Delivered through an integrated platform, Paysafe solutions are geared toward mobile-initiated transactions, real-time analytics and the convergence between brick-and-mortar and online payments.

Our supply chains

Our supply chains include suppliers of:

• IT hardware and software, including software licenses and open source software;
• data storage services;
• professional services from our advisers including our lawyers, accountants, auditors and public relations advisers;
• office equipment; and
• office cleaning and other office facilities services.

The vast majority of our suppliers are based in Europe and North America. They are required to take steps to prevent modern slavery and human trafficking in their own businesses and supply chains, whether under the Modern Slavery Act 2015 or equivalent legislation in other jurisdictions.

Where we use temporary or agency staff, we only use specified, reputable recruitment agencies and professional services firms. We maintain a list of approved agencies which is reviewed annually.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business and in our supply chains. This is managed through a tiered policy approach and the following key policies:

 

Paysafe Codes	The Paysafe Code	Our commitment to our culture and values is embodied in The Paysafe Code. This sets out the rules and guidelines that all employees at Paysafe are expected to follow and against which employees are held accountable. The standards reflect our commitment not just to law and regulation, but to the highest ethical standards that embody our core values of being Pioneering, Courageous, Open and Focused.
	Paysafe Partner Code	By working with Paysafe, suppliers accept the terms of our Partner Code which sets out Paysafe’s expectation that our partners, including suppliers and anyone that they in turn work with to deliver products and/or services to Paysafe, will comply with the principles in the Partner Code. It includes zero-tolerance for modern slavery and human trafficking, bribery and corruption, money laundering, discrimination and harassment, and standards for achieving consumer protection and fair dealing.
	Senior Managers’ Code	The Senior Managers’ Code sets out the responsibilities applicable to Senior Managers under Paysafe’s control framework and helps ensure we maintain high standards of business conduct.
TIER 1	Global Conduct & Ethics Policy	Our Global Conduct & Ethics Policy applies to all staff across Paysafe, to reflect and enforce our commitment to conduct all business in an honest and ethical manner. It focuses on controls relating to anti-bribery and corruption, conflicts of interest, whistleblowing and internal fraud.
	Global Compliance Policy	Our Global Compliance Policy sets the standards for preventing financial crime, managing sanctions and PEP risks, ensuring acceptable business practices, and maintaining compliance across all countries where Paysafe operates.
TIER 2	Modern Slavery and Human Trafficking Policy	Our Modern Slavery and Human Trafficking Policy sets out how Paysafe handles matters relating to modern slavery and human trafficking. The policy refers to the systems and controls in place to ensure slavery and human trafficking is not taking place anywhere in our business or in our supply chains.
	Procurement Policy	The Procurement Policy sets out Paysafe’s approach to the procurement of goods and services and the requirement to ensure a controlled, transparent, auditable and compliant procurement function. It also includes requirements related to preventing slavery and human trafficking in our supply chain.
	Sustainability Policy	This Policy sets out Paysafe’s strategic commitment and approach to sustainability.
	Anti-Bribery and Corruption Policy	Paysafe is committed to implementing and enforcing effective systems to counter bribery and corruption in line with all applicable laws. This policy sets out our responsibilities and those working for us, in observing and upholding our position on anti-bribery and corruption and provide information and guidance on proper reporting and recognizing appropriate gifts and hospitality.
	Whistleblowing Policy	The Whistleblowing Policy sets out how anybody who works for us or with us can express concerns about misconduct /wrongdoing and to encourage employees to raise these concerns at an early stage. It establishes procedures for the receipt, retention, investigation and treatment of complaints and concerns regarding accounting, internal accounting controls, auditing and other legal and regulatory matters regarding Paysafe and its subsidiaries.
	Conflicts of Interest Policy	This policy has been adopted to ensure that any actual, potential or perceived conflicts of interest are identified, reported and managed to avoid a conflict of interest adversely affecting the interests of Paysafe’s customers, merchants, shareholders or other stakeholders.
	Internal Fraud Policy	This policy sets out our responsibilities, and those working for/with us, in relation to preventing the incidence of internal fraud at Paysafe and provides information and guidance to those working for/with us on how to recognise and deal with internal fraud issues.
	Equal Opportunities Policy	This policy sets out Paysafe’s commitment to fair and non‑discriminatory employment practices, including merit‑based recruitment, equal treatment, and protections for part‑time and fixed‑term workers, supporting fair labour practices across our workforce.
	Anti-Harassment and Bullying Policy	This policy sets out Paysafe’s zero‑tolerance approach to harassment, bullying and abuse of power, including clear reporting, investigation and remediation processes, helping to prevent coercive or exploitative behaviour within our operations.

All policies are reviewed annually and undergo an established review and approval process incl. the senior management team.  

Employment Rights

Employment rights for Paysafe employees include:

• non-discrimination
• wage benchmarking
• freedom of association/collective bargaining
• forced labour
• working hours
• contingent workers

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. We have a dedicated Procurement team which works closely with our Legal, Compliance and Internal Audit teams.

We have a Global Procurement Policy in place to ensure a controlled, transparent, auditable and compliant procurement service. Suppliers are required to complete appropriate due diligence to ensure they are qualified to conduct business with Paysafe.

Our Group Procurement team take supplier management and performance seriously. Decisions on potential suppliers are taken based not only on price and delivery times, but other factors including the supplier’s ability to deliver while maintaining compliance with applicable laws and, where the supplier has previously been engaged by us, past compliance with Paysafe’s standards. Group Procurement monitor contractual performance by our suppliers and implement Continued Improvement Programmes (CIPs) with our suppliers where applicable.

Wherever possible, we seek to procure goods and services from an existing supplier already known to Paysafe, which allows us to better understand our suppliers’ operations and policies and to build strategic, long-term relationships with those suppliers.

To ensure all those in our supply chain and contractors comply with our values, we have a rigorous supply chain compliance programme in place. This currently consists of the following measures:

• Purchases from suppliers are made using either standardised contracting forms or a standard set of purchase order terms and conditions, which include:
  • a representation and warranty from the supplier that neither it nor any employee has been convicted of any slavery or human trafficking offence, nor been the subject of any investigation into any alleged slavery or human trafficking offence;
  • an obligation on the supplier to comply with all applicable laws, and specifically the Modern Slavery Act 2015;
  • audit rights for Paysafe (or an independent third party representative) to verify the supplier’s compliance with the terms; and
  • the right for Paysafe to immediately terminate the supply agreement if the supplier breaches its compliance obligations.

In addition, when conducting due diligence on potential suppliers, we require them to complete: (1) a detailed due diligence questionnaire, which covers topics such as supplier profile, size and history, and requires suppliers to provide references from previous business partners; and (2) a mandatory Environmental Social and Governance survey, which covers, inter alia, Modern Slavery Act compliance, Community, Diversity and Inclusion management, corporate governance and gender equality assessments. Specifically, this survey includes the requirement for the supplier to identify and document Modern Slavery prevention practices in place throughout its businesses and wider supply chain. This assists in identifying what systems and controls the supplier has in place to ensure slavery and trafficking are not taking place in any part of their business.

• Any supply agreements made on the supplier’s terms are duly reviewed by our Procurement and Legal teams to ensure that the supplier is obliged to comply with all applicable laws.

• By working with Paysafe, suppliers accept the terms of our Partner Code which sets out Paysafe’s expectation that our partners, including suppliers and anyone that they in turn work with to deliver products and/or services to Paysafe, will comply with the principles in the Partner Code and will share Paysafe’s commitment to conducting our respective businesses with integrity and in an honest and ethical manner. This Partner Code includes our requirements with regards to zero-tolerance for slavery and human trafficking.

Risk assessment

During 2025, we have continued to assess our business and supply chains to identify any particular sectors or geographies where there’s a greater risk of modern slavery or human trafficking and what measures are in place to mitigate those risks.

Specifically, this year, we engaged a third-party consultancy to conduct a review of our procurement processes, policies and practices, allowing us to identify supplier categories that give rise to higher environmental and social risk.

Based on this review, we identified the following industries as carrying a higher degree of environmental and social risk:

• Manufacturing related to POS equipment, products and merchandising 
• Those contracted to manufacture POS equipment, products and merchandising  
• Contact centre services 
• Bespoke software development 
• Catering or cleaning services

We take additional measures to reduce the risk related to these suppliers:

• our contracts with suppliers for the provision of cleaning services to our UK offices require the suppliers to comply with all applicable legislation and to meet all regulatory and industry standards in providing the services, and to ensure that sufficient resources are allocated to properly provide the services;
• when we procure Paysafe-branded promotional merchandise, this is sourced from a supplier which is a member of Sedex (the Supplier Ethical Data Exchange) who is accredited as an EcoVadis platinum standard supplier; and
• where we provide services to merchants who operate in sectors which carry a higher risk of modern slavery or human trafficking, we implement additional compliance controls, such as enhanced due diligence and validation of the merchant’s controls prior to onboarding, additional Paysafe senior management approval for onboarding, and additional ongoing monitoring.

Training and compliance

All Paysafe staff are required to read, understand and commit to follow our annually reviewed Conduct & Ethics online training and confirm their agreement to the Paysafe Code and supporting policies including the Paysafe Code, Global Conduct Policy, Global Compliance Policy, Anti-Bribery and Corruption Policy, Whistleblowing Policy, Conflicts of Interest Policy and Procurement Policy. In addition, on an annual basis, Paysafe’s senior managers are required to read and confirm their agreement to the Senior Managers’ Code.

All Paysafe staff involved in the procurement of global goods and services are required to comply with our Global Procurement Policy. New joiners are required to read and confirm their agreement to the Global Procurement Policy.

The completion is monitored daily and the automated training escalation process is applied. Failure to complete mandatory training or read and confirm agreement to relevant policies may lead to losing access to Paysafe e-mail and Teams and a reduction of 10% of the annual performance appraisal score is applied.

Whistleblowing

Paysafe has in place a global Whistleblowing Policy, which includes detailed whistleblowing guidance to enable and encourage all staff to express concerns regarding any misconduct or wrongdoing related to our business. This may be done either by raising a concern anonymously through our external whistleblowing channel, or by raising a concern directly to our designated non-executive director Whistleblowing Champion if that member of staff prefers to speak to someone outside the business. All reports will be investigated and appropriate remedial actions taken. Paysafe has a zero-tolerance policy to retaliation and will always maintain the whistleblower’s confidentiality, to the extent permitted by law. All staff are required to periodically complete an online training module which highlights these procedures.

Our effectiveness in combating slavery and human trafficking

In order to assess the effectiveness of the measures taken by Paysafe in combating modern slavery and human trafficking during 2025, we used the following key performance indicators (“KPIs”). The table below sets out the results of our monitoring of these KPIs and the actions taken to address any issues raised.

 

KPI	Results and Actions Taken
The proportion of Paysafe staff who have completed the Conduct & Ethics online training and confirmed relevant training or have otherwise confirmed in writing their agreement to the Paysafe Code and relevant policies and procedures	In 2025 new joiners were required to complete the Conduct & Ethics online training and confirm their agreement to the relevant policies (incl. Paysafe Code, Global Conduct Policy, Global Compliance Policy, Anti-Bribery and Corruption     Policy, Whistleblowing Policy, Conflicts of Interest Policy and Procurement Policy) within 30 days of joining Paysafe. As at 31 December 2025, 99%1 of new joiners had successfully completed the Conduct & Ethics online training and confirmed agreement to the policies. Any cases of non-compliance were escalated to management by following the established automated training escalation process until the training had been successfully completed. Existing staff are required to complete the Conduct & Ethics online training as a refresher training annually. As at 31 December 2025, 98% of existing staff had successfully completed the refresher Conduct & Ethics online training. Any cases of non-compliance in 2025were escalated to management by following the established training escalation process until the refresher training had been successfully completed.
Number of employees whose access to Paysafe e-mail and Teams was disabled due to non-compliance in the Conduct & Ethics online training and in confirming their agreement to the Paysafe Code and supporting policies.	As of 31 December 2025, 131 employees lost their access to Paysafe e-mail and Teams throughout 2025. The access was enabled once the overdue items were completed.
The percentage of whistleblowing reports made which related to slavery or human trafficking incidents.	No whistleblowing reports relating to slavery or human trafficking incidents were received.
The remedial actions taken in response to any investigations into reports of modern slavery or human trafficking.	No such reports were received.

We continue to assess these KPIs each year to consider whether alternative or additional KPIs would be more appropriate to measure the effectiveness of our actions.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Paysafe’s slavery and human trafficking statement for the financial year ended 31 December 2025.

This statement has been approved by the boards of directors of Paysafe Financial Services Limited, Prepaid Services Company Limited and Skrill Limited.

 

Signed by

Elliott Wiseman
Chief Legal Officer
Paysafe

August 2026

For the Paysafe Group’s Modern Slavery Act Transparency Statement for the year ended 31 December 2024, click here.
For the Paysafe Group’s Modern Slavery Act Transparency Statement for the year ended 31 December 2023, click here.
For the Paysafe Group’s Modern Slavery Act Transparency Statement for the year ended 31 December 2022, click here.
For the Paysafe Group’s Modern Slavery Act Transparency Statement for the year ended 31 December 2021, click here.
For the Paysafe Group’s Modern Slavery Act Transparency Statement for the year ended 31 December 2020, click here.
For the Paysafe Group’s Modern Slavery Act Transparency Statement for the year ended 31 December 2019, click here.
For the Paysafe Group’s Modern Slavery Act Transparency Statement for the year ended 31 December 2018, click here.
For the Paysafe Group’s Modern Slavery Act Transparency Statement for the year ended 31 December 2017, click here.
For the Paysafe Group’s Modern Slavery Act Transparency Statement for the year ended 31 December 2016, click here.