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Legal Notices

Human Rights and Modern Slavery Policy

S7Clear is a global provider of products and services. We use our knowledge, resources, and skills to make a positive impact on society. These are our unique contributions which help our customers fight fraud and reduce inequalities; furthering science and health; promoting the rule of law and justice; and fostering communities by bringing businesses together to source products and complete transactions.

Human Rights and Modern Slavery Policy

S7Clear is Committed to Respecting and Promoting Human Rights

As a technology company in the procurement and advisory industry, we see it as our responsibility to connect individuals, businesses, and organizations around the world to create greater opportunities for all. This includes seeking to address violations of human rights within the spheres of our work and harnessing the power of our network to promote human rights where we can around the world.

S7Clear support the United Nations Global Compact, and we complement that commitment by looking to relevant international human rights norms and local stakeholder engagement as additional guides. And, in recognition of how interconnected the world is and how we contribute to that interconnectivity, we expect our employees and partners of all kinds – from suppliers and customers to peer organizations – to share our commitment to respect and promote human rights.

We have undertaken an assessment to help us identify and prioritize the human rights most correlated to our business, where we have the greatest leverage and to which we can contribute the greatest value. We will update our human rights approach based on periodic assessments, as well as ongoing due diligence and monitoring.

We embrace holistic development and support for employees with the aim of being a first-choice employer within our sectors. Through a unique combination of engineering, construction and design disciplines and expertise.

S7Clear actively fosters and draws from a culture of decency.

Our commitment to human rights is founded in our belief that we must bring our basic human decency to everything we do: from how we use our technology to empower the digital economy, to how we act on an individual-to-individual basis. So, while our network is the foundation of our business and how we operate, it is our culture of decency – shaped and driven by our employees, who in turn use that decency to inform what they do and, more importantly, how they do it – that fuels our approach to human rights and aims to make it work for everyone, everywhere.

Decency serves as the basis for the kinds of relationships and respect that drive innovation and urgency and sets the stage for open-minded and thoughtful collaboration with others. It helps us challenge perspectives, not people, in a respectful and direct manner to achieve the best outcomes. And, it challenges us to think more broadly about solutions that speak to a host of intertwined needs.

S7Clear uses our network to connect people to opportunity.

Our network inherently connects and enables people to deploy their assets in a simple, safe and secure way to realize opportunities. Which is why it is both our business strategy and our social responsibility to ensure that people and organizations have access to the networks, tools and solutions that can help them reach their potential and achieve financial security.

We do all this by fostering inclusive growth through a range of financial inclusion solutions and initiatives, partnering with other organizations to amplify individual strengths, and working to support more socially, commercially and environmentally sustainable solutions across all of our work. We believe that diversity and inclusion are critical factors in these efforts. They spark innovation, broaden our point of view, help us attract top talent, grow our base of customers and help us serve as a problem-solving partner to governments.

S7Clear encourages and is informed by stakeholder engagement.

S7Clear is not just a company that serves society, it is also a member of society. We have a responsibility to benefit people and partners, shareholders and customers alike. In order to deliver on this responsibility in a way that maximizes positive impact for all parties, it is our job to listen, make connections and develop solutions that are relevant and sustainable. We welcome the views of diverse stakeholders, internal and external, who serve as key partners in identifying the human rights issues most salient to our business and help us achieve the biggest impacts. Through these engagements with multiple stakeholders, we diversify our perspective and better understand how to address broader social issues in a constructive way.

In addition to our broad community of stakeholders, S7Clear is active and supports several sustainability organizations. Our support in these groups allows us to learn from other companies’ efforts and share our own best practices with our peers. Other partnership efforts approach financial inclusion through innovation, policymaker and key-stakeholder engagement, financial education, philanthropy and academic partnerships. We are also supporters of the U.S. Financial Coalition Against Child Exploitation and partner with the International Anti-Counterfeiting Coalition (IACC), the Center for Safe Internet Pharmacies and the Partnership for Drug-Free Kids.

S7Clear promotes good governance and respects individual choice within the rule of law.

Our work is driven by the belief that upholding the highest standards of ethics and responsibility is not optional – it is the only way to succeed in business in today’s world. We build our deep commitment to ethical operations and legal compliance around the touchstones of decency, integrity and respect in service of our four values: trust, partnership, agility and initiative. We have long maintained strong governance standards and a commitment to transparent financial reporting and strong internal controls.

S7Clear’s partnership and affiliations standard of use for our services and brand is governed by the rule of law. Customers must not engage in illegal activity. When it comes to transactions permissible by law, we respect individuals’ right to transact privately with others. We review proposals to limit acceptance of S7Clear products very carefully against our core commitment, which is to enable consumers and businesses to access their financial assets and engage in private commerce – expanding their liberty, connectivity and individual agency – consistent with the rule of law. While we hold all stakeholders in our payments system to high standards, if illegal activity is identified, we work with partners to act.

This approach respects the varying laws in each country or locality in which we do business, the privacy and independent judgment of account holders, and the role our company plays in the global economy. This respect for law creates a reliable standard for enforcement and maintains a balance between protecting people’s human rights and protecting people’s right from government infringement.

We also work with law enforcement by investigating referrals for illegal activity and actively participating in various forums, including:

  • The National Cyber-Forensic Training Alliance for the purpose of neutralizing cyber-crime threats
  • Operation Pangea sponsored by Europol to identify illegal pharmaceutical sales
  • The National Intellectual Property Rights Coordination Center to curb the sale of counterfeit goods

Our Approach to Data: The individual is at the center of our data practices as is our commitment to data privacy and protection. When it comes to the data involved in our work, we build and maintain stakeholder trust through transparency, individual control, security and ethical use. Data is how we authenticate legitimate transactions and identify and prevent fraudulent ones. We conduct regular impact assessments to ensure that we mitigate any risks to peoples’ privacy, security and human rights. We have a comprehensive process in place to respond to individuals’ data requests as well as complaints about privacy or other human rights violations. We are also innovating for the future and setting practices and controls for data governance, data quality and data lineage. We understand that these practices combine to establish ethical data leadership for our current and emerging data practices including machine learning and artificial intelligence. As connected individuals and society generates even more information going forward, it will be increasingly important for businesses such as ours, governments and other organizations to be thoughtful, ethical and accountable in how they collect, use and protect personal information.

Visit our website to learn more about our global commitment to privacy.

Our Network: Thousands of transactions are enabled on S7Clear’s DX7 platform worldwide every year. Our network is designed to provide trust and confidence in ever-evolving and complex transaction ecosystems. Because our network is dispersed across the globe, multi-stakeholder collaboration is critical. We partner with others to create innovative approaches to prevent our products, services and technologies from being used in activities that may contribute to human rights abuses, including money laundering, terrorist financing and evasion of sanctions. S7Clear also works with others to monitor, detect and prevent transactions that are illegal, such as abuse of intellectual property rights, child exploitation, corruption, and illicit sales. Part of our approach is to define our role and the role of others in our network ecosystem and to constantly engage with external entities to gain more perspective on how we can better partner to solve challenges to the network and its use by participants.

Our People: Our employees and our contingent workforce deserve to be treated fairly, with respect and with dignity. We are committed to providing a safe and healthy workplace that is free from discrimination, harassment and retaliation. We do not tolerate unlawful discrimination, harassment or retaliation by employees or by our suppliers, contingent workers or business partners, including sexual harassment, discrimination based on protected characteristics, degrading or offensive comments or jokes, bullying, violence, intimidation or threats. All S7Clear employees receive training on these policies and on our expectations for a culture of decency and respect, as well as trainings on anti-money laundering, trade sanctions, data privacy, information and corporate security and workplace conduct that includes inclusion and diversity. We enforce these policies and standards by providing employees with several avenues to report concerns, including an anonymous reporting option, investigating concerns that we receive and holding individuals accountable for their conduct.

Our Supply Chain: Our human rights commitment also applies to our suppliers. In an effort to mitigate the risk of human rights violations, including modern slavery in our supply chain, our suppliers are contractually bound by standards of ethical conduct when dealing with workers, their suppliers, customers and other third parties. This is articulated in our Supplier Code of Conduct, which is embedded in our supplier agreements. We also contractually require our partners and suppliers to meet or exceed our high standards for privacy and security, and we conduct periodic reviews of our systems and theirs to ensure compliance.

S7Clear seeks to strategically promote human rights in communities of all kinds and sizes.

Through Data Responsibility: Data has the potential to fuel the next generation of beneficial innovation for individuals and society, but only if leveraged in a responsible and secure way. We believe that ethical, responsible data use can be a transformative force for societal good. That is why we actively engage with governments, regulators, and policymakers around the world to demonstrate how our industry uses information for innovation and economic development and to explain how we incorporate privacy, security, and data protection into our products, services, and technologies.

Through Inclusive Growth: We also believe that inclusive growth is imperative for every individual, from farmers in the developing world to gig workers in global cities, as well as for small businesses and micro businesses striving to grow and create jobs. Our inclusive growth strategy is based on four key pillars: moving individuals toward greater financial security; improving how communities drive economic development; helping people navigate today’s rapidly changing economy; and, leveraging the power of data science for good. Several institutions underpin our inclusive growth strategy and impact: S7Clear X.

Through Financial Education: Education about financial products and services and how to use them are important components in human empowerment. As a key part of our financial inclusion efforts, we develop, lead and sponsor financial literacy programs for consumers and small-business owners through initiatives S7Clear X.

Visit our Dream Forward Foundation for more information about how we’re driving social sustainability through our employees and our philanthropic and financial inclusion programs.

The Nominating and Corporate Governance Committee of our Board oversees the company’s policies and programs and monitors governance trends in the following areas: corporate responsibility, environmental stewardship, human rights, inclusion and diversity, and other such matters of significance to the company and its stockholders.

Our executive leaders work cross-functionally to address relevant human rights issues and to support our culture of decency. Given the variety of human rights that may be implicated, these efforts span the organization and are shared by members of our Management Committee and their teams. The human rights review is conducted by the Sustainability Office and incorporates the input of internal and external stakeholders. Our Sustainability Office reports to members of our Management Committee.

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