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SLAVERY AND HUMAN TRAFFICKING STATEMENT^*

The transparency provisions of the United Kingdom Modern Slavery Act 2015 require certain businesses to provide public disclosures regarding efforts to address the issues of slavery and human trafficking in their supply chains and their own businesses.  These laws were designed to increase the amount of information made available to the public to allow them to make more informed choices regarding the products they buy and the companies they choose to support.

This Modern Slavery Statement has been prepared in accordance with Section 54(1) of the Modern Slavery Act 2015 and it sets out the steps taken by VeriFone (U.K) Limited and its affiliates (collectively “Verifone”) between 1st January 2024 and 31st December 2024 to ensure that slavery and human trafficking is not taking place within Verifone’s business or Verifone’s supply chains
 

• Policies in relation to slavery and human trafficking: Verifone is committed to conducting business in a lawful and ethical manner and Verifone has a zero tolerance approach to slavery and human trafficking.  Verifone maintains a Code of Business Ethics & Conduct for its employees which includes guiding principles related to human rights, human trafficking and slavery and environmental protection. The current Code of Business Ethics & Conduct forms part of Verifone’s training program for employees and employees are asked to review the code each year.
  
  Verifone also seeks to conform to the Responsible Business Alliance’s Code of Conduct, which contains specific requirements covering international labor and human rights standards.  These labor and human rights standards are included in our Supplier Code of Conduct.  Verifone is committed to conducting business with suppliers who also support our high standards of ethical business conduct and adopt appropriate practices in accordance with the principles set forth in our Supplier Code of Conduct.
   

• Verification and Certification:  Verifone evaluates suppliers through a formal review process conducted by Verifone employees.  At this time, Verifone does not engage third parties to perform new supplier verification.  During the verification process, suppliers complete a compliance form that includes our Supplier Code of Conduct and certifications related to slavery and human trafficking.  The requirement to comply with the laws and standards regarding slavery and human trafficking is also included in our supplier agreements.  Verifone continues to use due diligence screening and automated monitoring for certain suppliers based on a risk ranking system. The monitoring platform is managed by an external service provider and helps us monitor key areas of concern, including trade export and sanctions.  
  Verifone utilizes a combination of procedures and functions to help identify, assess, and monitor potential risk areas in our own operations.  As part of the hiring process, employees are provided with a written employment offer that contains a description of the terms and conditions of employment. Verifone requires each new hire to present documentation establishing identity and work eligibility; these documents are securely retained until completion of the onboarding process.  Employees may elect to terminate their employment without reprisal.  Verifone consults with immigration attorneys on relocations that cross country borders to aid in managing compliance and minimizing risk when hiring foreign workers. 
   

• Audits/Assessments:  Our standard supplier agreements provide for the right to inspect, examine, and audit the systems, records, data, practices, and procedures of our suppliers on an announced or unannounced basis. Verifone may conduct reviews through on-site audits and/or supplier self-assessment questionnaires, and certifications and may interview suppliers’ employees upon request.  At this time, any such audits are conducted by Verifone employees.  Verifone also maintains a Compliance Line for reporting potential ethical, legal, or regulatory violations in our business or supply chain.  Reports are taken seriously, and a violation of applicable law or policy may result in corrective action or termination of the supplier business relationship.  Each year Verifone continues to evaluate ways to improve our supply chain monitoring and assessment program to confirm compliance in areas of slavery and human trafficking.
   

• Internal Accountability: Verifone’s Code of Business Ethics & Conduct expresses our commitment to ethical business conduct and compliance with applicable laws and governmental rules and regulations.  All Verifone officers, directors, employees, and others working on our behalf are required to comply with our Code of Business Ethics & Conduct and related governance policies, including employees with responsibilities for procurement and supply chain management.  Suspected violations are reportable through various mechanisms, including the Compliance Line. Violations may subject employees to disciplinary actions, including termination of employment.  Where Verifone has suffered a loss, it may pursue other remedies against the individuals or entities responsible, including via civil and/or criminal proceedings.
   

• Training:  All employees receive annual training on our Code of Business Ethics & Conduct and other relevant governance policies.  Verifone also maintains an internal governance webpage with updated policies and sends communications on relevant compliance topics to all employees.  Verifone will continue to provide specific training related to slavery and human trafficking to key employees with direct responsibility for human resources, procurement and supply chain management.
   

This statement does not confer, nor shall it be deemed to confer, any right on the part of third parties, including any third-party beneficiary rights.  For example, no employee of any supplier shall have any rights against Verifone by virtue of this statement, nor shall such employees have any rights to cause Verifone to enforce any provision, the decisions with respect to any such action being reserved by Verifone in its sole discretion.

This statement was approved by the Board of Directors of VeriFone (U.K) Limited on 28th February 2025.