Pursuant to Section 54 of the Modern Slavery Act 2015, this statement outlines Brisk Pay Ltd’s approach to modern slavery and human trafficking for the financial year ending 31st FEB 2026.
Modern slavery and human trafficking are global crimes that are prevalent not only abroad but also within the UK. According to the Home Office’s 2021-2022 UK Annual Report on Modern Slavery, detection and prevention remain critically important in the UK as much as they are worldwide.
This statement applies to all companies and subsidiaries within Brisk Pay Ltd and was originally approved by Brisk Pay Ltd’s CEO on 19th February 2025, subsequently ratified by the Board.
Our Organisation
Brisk Pay Ltd is a provider of financial services. Founded in 2025, Brisk Pay offers a modern way to transfer funds via technology and transparency in the financial services sector, catering to both business and retail customers.
Through our subsidiaries, Brisk Pay will be authorised by the FCA and HMRC in the future. We will have Tier-1 bank-grade functionality with the Bank of England and direct connectivity with the UK payments network. Our products range from our own brand payment accounts for individuals and businesses to a variety of FX solutions and payment transfers.
Brisk Pay Ltd has approximately 5 staff based in the United Kingdom (London), along with 2 employees based in our UAE offices. As these staff members are directly employed by Brisk Pay Ltd and are not in positions that pose a risk for modern slavery or human trafficking, our focus is on managing the supply chain of firms within Brisk Pay Ltd.
Our Supply Chain
As a provider of user-centric technology that enables clients to make payments and deliver foreign exchange services in a cost-effective manner, a significant portion of the technology is built and maintained in-house. However, the company relies on a relatively small supply chain for certain services and partners that enable the day-to-day operations of our technology services.
Additionally, outside of the technology sector, Brisk Pay acquires a variety of goods and services, such as professional services, contractors, and consumables.
These suppliers, which range from small to medium-sized businesses to multinational corporations, are primarily based in the United Kingdom, with some located within the European Union and beyond.
Our Policies
Brisk Pay Ltd believes it has a responsibility to uphold the rights and freedoms of individuals employed directly by the company, as well as to implement policies to mitigate and eliminate the risk of modern slavery and human trafficking within its supply chain. These policies are reviewed annually. These include:
Modern Slavery and Human Trafficking Policy
Supplier Onboarding Policy
Whistleblowing Policy
Anti-Bribery and Corruption Policy
Our Due Diligence
Brisk Pay Ltd is committed to actively monitoring and detecting modern slavery and human trafficking.
All suppliers are asked to complete a Supplier Due Diligence and Security Questionnaire to ensure compliance with the Modern Slavery Act 2015 or equivalent local laws. Suppliers are required to inform Brisk Pay Ltd of their compliance with the Modern Slavery Act 2015 and how they will notify the company in case of suspicion or knowledge of modern slavery or human trafficking related to any of their contracts with Brisk Pay Ltd.
Where the company uses suppliers outside the United Kingdom, we ensure that the jurisdictions in which these suppliers operate have legislation that treats modern slavery and human trafficking as serious criminal offenses, as highlighted in the UNODC’s Global Report on Trafficking in Persons.
Should a supplier fail to submit a completed Supplier Due Diligence and Security Questionnaire or fail to meet compliance requirements, the company will take appropriate action, which may include terminating the supplier relationship.
Our Training
Throughout 2025, the Board of Brisk Pay Ltd has focused on strengthening our stance on modern slavery and human trafficking, building upon the foundations outlined in our Modern Slavery and Human Trafficking Policy. Relevant staff receive a comprehensive compliance induction, regular training sessions, and participate in active working groups and committees that ensure our standards are continually updated.
We believe an open, collaborative working environment is crucial for the success of the company. Staff and suppliers are encouraged to voice concerns or suspicions regarding modern slavery and human trafficking without fear of reprisal.
We remain committed to evolving our approach to modern slavery and human trafficking and are dedicated to upholding these shared values across Brisk Pay Ltd.
Joelle Manih
Director
For and on behalf of the Board of Brisk Pay Ltd
19 February 2025
