Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and 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.

We are committed to preventing slavery and human trafficking in our operations and supply chains. We have taken steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to better understand all potential modern slavery risks related to our business.

Our Business and Supply Chains
We are a provider of payment processing services in the Visa USA and Europe regions.

Our supply chain consists of the procurement of various goods and services. We form relationships of trust and integrity with all our suppliers, which are built upon mutually beneficial factors. Our supplier selection and onboarding includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, as well as requesting references as may be necessary.

Our Policies on Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

We have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.

Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We strive to continually develop and improve our existing policies and processes to ensure that appropriate systems are put in place to better evaluate and be more effective at preventing modern slavery in our supply chains.

Due Diligence Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk, we have in place systems to:

• Identify and assess potential risk areas in our supply chains
• Mitigate the risk of slavery and human trafficking occurring in our supply chains
• Monitor potential risk areas in our supply chains

• We assess risks in the provision of particular services
• We audit suppliers and their health and safety standards, labour relations and employee contracts when and as necessary
• We require improvements to substandard employment practices when and as necessary
• We sanction suppliers that fail to improve their performance in line with our requirements

• Legal
• Compliance
• Executive

Our compliance team is led by our Chief Compliance Officer (CCO).

We intend to assess our policies and procedures every year to consider whether alternative or additional provisions would be required to measure the effectiveness of our actions.

This statement is made on behalf of all entities within our group.

EPOCH
Summit Building
3415 North Pines Way
Suite 206
Wilson, Wyoming 83014

PHONE: +1 (307) 222-6996
PHONE: +1 (800) 893-8871