MODERN SLAVERY ACT

Introduction

eNett International (Singapore) Pte Limited and its subsidiaries (eNett) has a zero-tolerance approach to modern slavery and is fully committed to preventing slavery and human trafficking in its operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year ending 31 December 2020.

Our business and supply chains

eNett is a technology service provider that allows travel agencies to generate a unique 16-digit Mastercard number used to pay travel suppliers quickly, efficiently and with less risk. eNett is focused on B2B payments and relies on multiple suppliers to provide its services.

The countries/locations where eNett company operates:

  • Singapore
  • United Kingdom
  • Jersey
  • Australia
  • Hong Kong
  • New Zealand
  • United States

 

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety, and environmental standards, and references.

Risk Assessment

eNett conducts risk-based due diligence and assessments of its key suppliers before entering into a relationship with them and on an ongoing basis to identify those suppliers, it considers to be most at risk of having slavery or human trafficking in their business or supply chains. This assessment will determine our response and the risk controls that we implement.

eNett conducts risk assessment of its supply chain by taking into account:

  • country risk
  • customer risk
  • industry sector risk
  • transaction risk
  • business partnership risk

 

Policies

Slavery and human trafficking are serious criminal activities, and eNett and its subsidiaries will not knowingly support or do business with any organisation involved in such activities.

eNett operates the following policies for identifying and preventing slavery and human trafficking in its operations:

  • Enterprise Risk Management Policy
  • Vendor Outsourcing & Management Policy
  • AML Policy
  • Whistleblower Rights & Protections Policy
  • Code of Business Ethics & Conduct

 

eNett continually monitors and reviews its corporate policies and associated procedures to ensure that both its existing and new policies and procedures meet its obligations under the Act and as set out in this statement. eNettl requires all employees to review and acknowledge the terms of the above policies upon joining the company and on a periodic basis thereafter.

Awareness

eNett has raised awareness of modern slavery issues by educating and providing training that is focused specifically on modern slavery to all our staff, which explains:

  • Our commitment in the fight against modern slavery
  • Red flags for potential cases of slavery or human trafficking
  • How employees should report suspicions of modern slavery

 

Effectiveness 

We haven't been made aware of any allegations of human trafficking/slavery activities against any of our suppliers in the last financial year, but if we were, then we would act immediately against the supplier and report it to the authorities.

This statement is made pursuant to Modern Slavery Act 2018 (Cth) and covers 1 January 2020 to 31 December 2020 and has been approved by the Company. This statement will be reviewed and updated annually.